Privacy Policy

INTRODUCTION and IDENTIFYING the CONTROLLER of your personal data

Star Pubs & Bars Limited and Heineken UK Limited ("we", "us", or "our") are part of the Heineken group. Unless we inform you otherwise, the controller of your personal data will be Star Pubs & Bars Limited. Where Heineken UK 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 policy or our processing activities, we can be contacted as follows:

Mail: 3 – 4 Broadway Park South Gyle Broadway Edinburgh EH12 9JZ, marked for the attention of the Privacy Officer;
or
Email: protectingyourdata@heineken.co.uk

It is important that you read this privacy policy together with our cookie policy and any terms of use that apply to the services or websites which are presented to you. This privacy policy supplements the other policies and is not intended to override them. If you submit orders through Star Pubs & Bars Online, please review the privacy policy available on the Star Pubs & Bars Website which describes how we look after any personal data that you submit through that website.

SUMMARY and KEY POINTS you should be aware of

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 it may be given to us by third parties where you have given permission for data sharing or if the information is publicly available.

We use your data for various purposes, including to communicate and manage our relationship with you, protect our business, ensure we comply with laws and to run competitions and promotions. Transparency is important to us, so we would particularly like to highlight the following activities we conduct where we have a lawful basis (see the section headed "What is our LAWFUL BASIS for collecting your Data?") below:

We may use your data to create a profile of you. We may combine the data that you have provided to us with information from third parties and publicly available sources in order to better understand your interests. We want to build a profile of you so that we can send relevant communications and market to you more effectively.
We may use your data to send you online targeted advertisements. Based on our profile of you, we may present you with adverts when you browse online or use the Star Order App in order to market to you. This involves asking a platform to show our adverts to a particular group of individuals, and may involve using data purchased from third parties to help identify relevant audiences for our adverts.
We may use your data to conduct analytics. For example, we may track how you respond to the emails we send you. We want to see whether you open our emails and/or click on any content, so that we can understand and improve our approach to marketing.

You have various rights regarding our use of your data, see the section headed "What are my RIGHTS?" below.

HOW and WHAT data do we collect about you?

This privacy policy describes how we look after your personal data collected directly when you engage with us including when you (i) apply to become a tenant/operator at one of our pubs; (ii) take on the role of tenant/operator at one of our pubs; (iii) act as a guarantor to support a tenant/operator’s application; (iv) visit our websites; (v) contact us via email or telephone with an enquiry or complaint; (vi) take part in a competition; (vii) visit one of our sites, attend one of our events or an event/festival that we sponsor; (viii) purchase our products or services; and/or (ix) provide your contact details when you visit one of our pubs in order to assist the NHS England Test and Trace, NHS Wales Test, Trace, Protect and NHS Scotland Test and Protect programmes ("Engagement"). We collect this information for the reasons outlined in the section headed "WHY do we collect your personal data" below – described further in Annex 1.

We also collect information indirectly: (a) from Wireless Social where you visit a venue in which we sponsor the Wi-Fi services; and (b) from social media platforms (e.g. Facebook, Instagram and LinkedIn) (“Social Media Platforms”) and from third party data brokers (together “Relevant Third Parties”).

We collect different categories of information which we have grouped together as follows:

Identity Data - name, username, title, place and date of birth and personal characteristics including age and gender;
Contact Data - billing address, delivery address, forwarding address, email address and telephone number;
Applicant Data - work history, qualifications, National Insurance number, right to work documentation and proof of identity;
Financial and Transactional Data - credit history, bank account and card payment details, and details about payments as well as products and services purchased from us;
Profile Data - preferences, feedback, survey responses and interests including activities noted on Social Media Platforms (for example, your Facebook likes/groups), or collected from other Relevant Third Parties;
Technical and Usage Data - information about how you use our products, websites (including your IP address and details about the devices you use to access our websites (please review the cookie policy on each website for further information on this)) and transcripts of live chat support session that you generate on our Star Pubs & Bars website*;
Marketing and Communications Data - preferences in receiving marketing and communications from us and information in terms of engagement with email communications;
Location Data - GPS-based location information from your use of our websites or Social Media Platforms via your smartphone(s), tablet(s) or other devices;
Photo and Video Data - photos and/or video footage of you captured when you attend any events hosted or sponsored by us (your attention will be drawn to any photography or filming that is taking place, and your consent will be obtained where required); and
Inferred Data - which is inferred or derived from the data we collect, for example inferences about your interests based on your Identity Data, Profile Data, Technical and Usage Data or Location Data.

We 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 or visiting venues where we supply our products. 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:

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 genetics and biometric data). Nor do we process any information about criminal convictions and offences; or
Collect personal data relating to children. We have age verification processes on our websites to ensure we do not market our products or brands to anyone under the age of 18.

WHY do we collect your personal data?

We may collect the above categories of personal data about you for the following purposes (more specifically described in Annex 1):

To run our applications process;
To conduct market research;
To communicate with you;
To perform a contract we have in place with you;
To deter crime and ensure the personal safety and security of visitors and staff through the use of CCTV in our managed pub estate;
To protect our business, comply with our contractual or regulatory obligations and prevent or detect crime;
To market to you;
To enable you to partake in a promotion and for prize fulfilment purposes;
For analytical purposes;
To improve our products and services;
To maintain and optimise our websites;
To satisfy our legal and regulatory obligations and co-operate with regulators and government bodies; and
To defend and exercise our legal rights, including in relation to managing actual and potential claims.

What is our LAWFUL BASIS for collecting your personal data?

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 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 lawful basis which allows us to do so.

If you provide us with your consent to processing either in connection with your use of our website(s), through a Social Media Platform or a Relevant Third Party, 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.

WHO do we SHARE your personal data with?

We may share your personal data with the parties set out below:

Internal third parties - other companies in the Star Pubs & Bars/Heineken group based within the EEA and the UK;

External third parties – which include:

service providers such as solicitors, accountants, surveyors, insurance companies and insurance claims managers stock takers, providers of property repair and property security services, payment processing providers and distributors who assist us to ensure that we meet our legal and regulatory obligations (e.g. property maintenance, health and safety, tax and pubs code compliance), and in order to fulfil our obligations under the terms of our tenancy agreements;

suppliers such as training suppliers, satellite TV, Wi-Fi , dispense monitoring (e.g. Vianet), financial monitoring (Innside Track) and web-hosting companies in order to fulfil any requests that our tenants have made for those services;

credit reference agencies (“CRA”) - where you submit an application to become one of our tenants, 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 on the Experian website.

independent debt recovery and tracing agencies for the purpose of collecting monies due or outstanding on our tenants’ accounts;

regulators (Pubs Code Adjudicator), local licensing authorities, the Health & Safety Executive, the Police, HMRC and any other regulator or public authority, government agency, tax authority, or any agent thereof, with jurisdiction over us, to comply with any legal or regulatory requirements or investigations (including informal investigations)

the provider of the contact centre software which powers our live chat support service, to allow us to provide a more streamlined experience for prospective tenants/operators;

IT and system administration service providers (including data storage providers and data management platform providers);

selected third party providers of video interview software services;

operators of our managed outlets for the purposes of fulfilling table bookings that you have submitted through our managed outlet websites;

first and third party advertising companies and media agencies for marketing and research purposes and to provide promotion services, data on-boarding services, research and marketing strategy services;

prize fulfilment agencies;

third party providers of Social Media Platforms (including Facebook, Instagram and LinkedIn);

communications platform providers (i.e. vendors we use to send and manage email and SMS communications);

our energy scheme operator, Inspired Energy;

our draught dispense equipment service provider, Serviced Dispense Equipment Limited, and its subcontractor, Innserve Limited, to install, maintain, repair, replace and/or remove dispense equipment;

utility suppliers and local authorities (or such other third parties as may bring a claim for outstanding payments against us, e.g. Sky) in connection with the change of tenancy or sale process;

NHS England Test and Trace, NHS Scotland Test and Protect or NHS Wales Test, Trace, Protect in connection with the collection of contact details at our pubs for COVID-19 contact tracing purposes;

courts, parties to litigation and professional advisers where we reasonably deem it necessary in connection with the establishment, exercise or defence of legal claims; and

a purchaser or parties interested in purchasing any part of our business (and professional advisors supporting on the transaction).

International transfers

Third parties we share data with may be based outside the UK or the EEA. Whenever we transfer your personal data out of the UK or the EEA, we take steps to ensure that the same level of protection is afforded to it by ensuring one of the following safeguards is 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 and/or the UK Information Commissioner's Office. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries and ICO: International Data Transfer Agreement and Guidance; and
Where we use certain service providers, we may use specific contracts approved by the European Commission and/or the UK Information Commissioner's Office which give personal data the same protection it has in Europe (or the United Kingdom). For further details, see European Commission: Model contracts for the transfer of personal data to third countries and ICO: International Data Transfer Agreement and Guidance.

How SECURE is my data?

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 websites 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.

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, 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.

What are my RIGHTS?

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.

Right of access. You have the right to ask us for copies of your personal data. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can read more about this right here.
Right to rectification. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about this right here.
Right to erasure. You have the right to ask us to erase your personal data in certain circumstances. You can read more about this right here.
Right to restriction of processing. You have the right to ask us to restrict the processing of your information in certain circumstances. You can read more about this right here.
Right to object to processing. You have the right to object to processing of your personal data where we are relying on a legitimate interest or conducting direct marketing. You can read more about this right here.
Right to withdraw consent. Where we are relying on consent to process your personal data, you may withdraw it at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
Right to data portability. This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent. You can read more about this right here.

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 March 2022.

Annex 1 - PURPOSES, OUR LAWFUL BASIS, RETENTION PERIODS

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest	Retention period
To process your application to become a tenant/operator in one of our pubs which includes verifying your suitability as a tenant/operator through anti-money laundering and credit checks, as part of our application process.	Identity Contact Applicant	Necessary for our legitimate interests (recruitment of tenants/operators and internal administration).	Where your application is successful, 6 years following termination of the relationship. Where your application is unsuccessful, 6 months after notifying you that it is unsuccessful. If we perform a video interview with you, we will retain your data for 180 days from the date of collection.
To register you as a new tenant/operator if your application is successful.	Identity Contact Applicant	Performance of a contract with you.	6 years following termination of the relationship.
To conduct market research with unsuccessful or withdrawn candidates, as part of our application process.	Identity Contact Applicant	Necessary for our legitimate interest (to improve and streamline application process).	2 weeks after notification to you that your application was unsuccessful/after you have withdrawn your application (as applicable).
To add unsuccessful applicants to our talent bank of excellent candidates so that we can contact you when suitable opportunities to become a tenant/operator of one of our pubs arises, as part of our applications process.	Identity Contact Applicant	Consent.	Contact details are removed from our talent bank after three unresponsive contacts have been made to you, or if you notify us that you no longer wish to be contacted by us (whichever is the earlier).
To communicate with you and improve our services with you, which includes: managing our relationship with you; responding to enquiries from you; recording customer calls to our Customer Hub for quality and training purposes; investigating and responding to complaints or enquiries; sending you newsletters or alerts that you have asked to receive; inviting you to events; making suggestions to you about various products and services that you could benefit from; liaising with you in relation to any incidents at one of our pubs; notifying you about changes to our terms or privacy policy; asking you to complete surveys about how we can improve the services we offer you; and asking you for information on how we can improve our websites or our Engagements with you.	Identity Contact Profile Inferred Technical and Usage Marketing and Communications Call Recording (Note: 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).	Performance of a contract with you. Necessary for our legitimate interests (for running our business and managing our pub estate, improving our services through customer feedback and use of real calls for training purposes). To perform our legal obligations. You will be notified that calls are being recorded at the start of the call. If you object to the call recording, you will have the option to end the call and contact us through alternative means.	Recorded calls will be retained for 400 days from the time of the relevant call. Where you have contacted us in connection with an enquiry or compliant, we will retain your data for 3 years from when the enquiry or compliant has been resolved. Transcripts of all live chat support sessions that you generate on our Star Pubs & Bars website will be stored for 30 days for quality assurance and customer service purposes. If you no longer wish to receive any e-mails/alerts from us, you can unsubscribe at any time, and we will remove your email address within 1 month of receiving your unsubscribe notification, unless it requires to be retained for other purposes as listed in this privacy policy. Survey feedback will be retained until it has fulfilled its intended purpose (Note: please see section above “How LONG my personal data will be used for?” to learn more about the things we consider when determining how long we will retain your personal data).
Where we perform the contract we have in place with you, including managing payments, fees and charges, and delivering the requested product or service.	Identity Contact Financial and Transactional Data	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.
To deter crime and ensure the personal safety and security of visitors and staff through the use of CCTV in our managed pub estate.	Identity	Necessary for our legitimate interests (to protect the safety and security of visitors and staff at our sites and assist in criminal investigations).	Video footage will be retained for a limited time before it is automatically deleted. The retention of CCTV is determined by any specific requirements as specified by the local licensing authority in the premises licence, as well the need to investigate health and safety incidents or criminal incidents, including in connection with any legal proceedings or requests from law enforcement authorities, loss adjusters and insurers.
To protect our business through compliance with contractual or regulatory obligations, prevention / detection of crime and satisfaction of our legal obligations / defence of our legal rights, including: providing third parties (e.g. local authority and utility suppliers) with Contact Data for forwarding purposes of any incoming/outgoing tenants/operators or owners as part of the change of tenancy or sale process or to protect our business against unpaid or incorrectly enforced liabilities; complying with requests (including informal investigations) or demands of regulators and other bodies having jurisdiction over us; investigating security incidents on our websites; detecting and preventing spam, fraudulent activity, network exploits and abuse on our websites; and securing our websites against fraud. Note: in sharing forwarding addresses with third parties, we may rely on the exemption in Schedule 2, Part 1, Paragraph 2(c) of the Data Protection Act 2018 (the "crime and taxation" general exemption).	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.	Where you have contacted us in connection with an enquiry or complaint, we will retain your data for 3 years after the enquiry or complaint has been resolved. The cookie policy on the relevant website provides more information on specific cookie retention periods. 6 years following termination of the relationship.
To share photo and/or video footage captured at public or private events in external publications, on social media, with marketing agencies	Photos and video data.	Necessary for our legitimate interest (to promote and grow our business).	Until an op-out/objection is received or consent is withdrawn as applicable.
To send you online advertisements or marketing which isn’t direct to you but forms part of a wider brand campaign or initiative. Note: information for this purpose may be collected indirectly. See Annex 2 for more information on our marketing and profiling activities.	Identity (limited to age and gender) Profile Marketing and Communications	Necessary for our legitimate interests (to maintain the relevance of our brand and reputation and to grow our business by serving consumers with advertising relating to our brands). Where required by privacy laws, consent.	Data will be processed until an opt-out / objection is received or consent is withdrawn as applicable.
To send you direct electronic marketing (i.e. via SMS, email or direct messaging through Social Media Platforms) relating to our brands which we consider may be of interest to you. Note: information for this purpose may be collected indirectly. See Annex 2 for more information on our marketing and profiling activities.	Identity Contact Profile Marketing and Communications	Consent.	Data will be processed until an objection is received or consent is withdrawn as applicable.
To enable you to partake in promotions and for prize fulfilment purposes, including: prize with purchase promotions (including giveaways, instant wins and online, mobile, social media and app entries); loyalty and reward schemes; activity challenge; sweepstakes, scratch card and raffle style promotions (including instant wins and online, mobile, social media and app entries); sampling and point of sales promotions; and geo-targeted activities (including gamification and SMS).	Identity Contact	Performance of a contract with you.	6 months following prize fulfilment (in certain cases the retention period may be longer due to the nature of the prize e.g. flight tickets – in such cases the personal data will be deleted when it is no longer required).
To conduct data analytics to improve our websites, products/services, marketing strategies, customer relationships and experiences and enrich existing profiles using third party data, so that we can issue relevant marketing content and offers and analyse email engagement. This includes: creating individual profiles and profiled audience segments (including custom audiences) so that we can issue tailored marketing content and offers, in particular when we sponsor Wi-Fi services or use data management platforms; sending you targeted content based on your location and interests; ‘matching’ data we have collected, such as your e-mail address, with your profile on a Social Media Platform or data collected by Relevant Third Parties so that we can show you marketing content which may be of interest to you (for example, by using Facebook Custom Audiences); using tracking technologies to understand how you respond to our emails (for example, whether you open the email, click-through links and/or unsubscribe); identifying what subjects are of most interest to our users; and assessing the success of our marketing campaigns and communications. Note: information for this purpose may be collected indirectly. See Annex 2 for more information on our marketing and profiling activities.	Identity Profile Marketing and Communications Technical and Usage Inferred Location	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy). Where required by privacy laws, consent.	Data will be processed until an opt-out / objection is received or consent is withdrawn as applicable. The cookie policy on the relevant website provides more information on specific cookie retention periods.
To maintain and optimise our websites which includes where we need to solve performance issues, including troubleshooting, testing, system maintenance, support, reporting and hosting of data, to improve the availability and functionality of the websites and to improve the quality of our live chat support service.	Identity Contact Profile Technical and Usage	Necessary for our legitimate interests to maintain the relevance of our brand and reputation, run our business, operate administration and IT services, protect network security and to prevent fraud). Necessary to comply with a legal obligation.	We retain information relating to the performance of our websites for 2 years.
To collect your contact details when you visit one of our pubs in accordance with our legal obligation to assist the NHS England Test and Trace, NHS Wales Test, Trace, Protect and NHS Scotland Test and Protect programmes, in order to satisfy our legal obligations. Note: we will only share details collected about you for this purpose with NHS England Test and Trace, NHS Wales Test, Trace, Protect or NHS Scotland Test and Protect if requested, and your details will not be shared or used for any other purpose.	Identity Contact (Limited to first name, surname, telephone number, the date, time and name of the pub visit)	To comply with our legal obligation to conduct contact tracing in Scotland, England and Wales.	21 days from the date of collection.

*Please note that the live chat support service is only available on https://www.starpubs.co.uk/ and is not currently available on individual websites for our Just Add Talent managed outlets.

Annex 2 – MARKETING and PROFILING in more detail

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We will only send direct electronic marketing (e.g. via emails or SMS or direct social media messages) where:

we have your consent;
you have solicited certain information (for example to receive one-off correspondence in relation to a competition/promotion you have entered or a festival that we are sponsoring); or
you have purchased goods or services from us and you did not opt-out of receiving any marketing where this opportunity was provided to you.

You can ask us to stop sending you direct 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 direct electronic 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 may also receive indirect marketing from us by way of online advertisements or general marketing communications from us. There are various methods we may use in order to indirectly market to you online, as follows:

Contextual advertising on particular types of websites - we buy space on these third party websites and our adverts are shown based on other content displayed on the page: it is not targeted to particular individuals.
Advertising to people signed up with an online platform (such as Facebook or Google) based on what the platform knows about them, e.g. we may ask Facebook to show a particular advert to people interested in beer living in Edinburgh or in certain competitions / events (including festivals). This may involve use of ‘custom audiences’ where we send a list of hashed email addresses of our existing customers (including end consumers) to the online platform, and the online platform then matches these email addresses to users and presents our advertising to them. Hashing is a security measure whereby the information is turned into a code.
Identifying relevant groups of people who aren’t existing customers - we use data purchased from third parties to identify relevant audiences who our adverts might be of interest to.
‘Look-alike” / ‘Similar’ audiences, where either: (a) we use our “custom audiences” (see point 2 above) to find a group of people with similar characteristics to our existing customer base; or (b) as an expansion of the activities described in point 3, we ask third parties to present general social media adverts to individuals that they believe will like our products based on audience data within their platforms so that we reach the right audiences and ensure our marketing efforts are efficient. For the circumstances in (b), we would direct the third parties to target individuals in certain age categories and locations with certain interests. In each case, we only receive anonymised reporting (e.g. number of impressions) and you won’t receive direct marketing (e.g. SMS/e-mails) unless you have consented to that. In these circumstances, the platform and Relevant Third Parties act as a controller. Further information about how the platforms, including Facebook Ireland, process your personal data can be found in their respective privacy policies.

Profiling

We may use your Identity Data, Contact Data, Profile Data, Technical and Usage Data, Marketing and Communications Data and Location Data, together with Inferred Data, to form a view on what we think you may want or what may be of interest to you and to understand your purchasing trends. We may also use data which has been collected from third parties to enrich the data we hold relating to you in order to build a fuller picture of what may be of interest to you. These profiling activities inform how we decide which brands, products, outlets and offers may be relevant to you, and to send you tailored communications in order to make personalised recommendations, inform you of special offers we think you will be interested in and customise promotions & special offers that are most relevant to you across a variety of channels for all relevant Heineken products. In more detail:

In order to create a profile for you, we (or our trusted service providers) may use the information which you give us and which we collect from external resources, such as our data broking partners, including information that is publicly available about you. We may also combine your information with data already held internally by us. We also use third parties for behavioural analysis, to help us segment our consumer database (i.e. to put you into categories with other people who have expressed an interest in products like ours, with similar characteristics). We also use software tools to help us analyse/predict who is most likely to buy our products and to target our engagement more accurately with you.
When you receive an email from us, we may receive certain information about how you interact with that email. The information we collect includes the number of times you have opened the email; if you have clicked links in the email; whether you have unsubscribed or marked the email as spam; whether the email has bounced; whether you have shared the information on social media or forwarded it to friends. This ensures you do not receive irrelevant or unwanted emails, as well as allowing us to use our resources efficiently.

When you visit one of our websites, you can use the cookie banner to accept or reject non-essential cookies, including advertising cookies. If you accept them, these cookies will record information about how you interact with our websites and this information will then be used to serve you with relevant adverts on other sites based on the content that you have clicked on or interacted with. We may use information collected via cookies when you visit our websites and aggregate this with information gathered via the relevant websites to understand your preferences/interests and ensure marketing/remarketing is relevant. Please see our relevant cookie policy on the website you browse when accepting cookies for more detail on this and how to control your preferences. Please note that whilst we carry out 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.

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