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Privacy policy
Effective from  20.09.2022.

1. INTRODUCTION

This Privacy Policy (‘Policy’) applies to this website (‘Website’) where we, HEINEKEN Hrvatska d.o.o., Karlovac, Dubovec 22, (‘we’, ‘us’ or ‘our’) collect certain personal data in the capacity of the data controller. We are part of the HEINEKEN Group. However, where processing is undertaken for the purpose of globally strategic reporting & insights and marketing activations, HEINEKEN International B.V. is regarded as a separate data controller of your Personal Data.
Please read this Privacy Policy carefully as it contains important information to help you understand our practices regarding any personal information that you give to us or that we collect otherwise in the context of the Website (‘Personal Data’). This Policy can be updated from time to time. You will be informed about any changes and/or additions to this Policy via this Website or by any other appropriate means, to the extent that is reasonably possible. We recommend that you occasionally check if the Policy has been changed since your last visit with respect to the date specified under its title.

2. WHAT PERSONAL DATA WE COLLECT AND HOW WE USE YOUR PERSONAL DATA

You can use the majority of our Website without being required to provide any Personal Data to us. For certain services or activities, you will need to provide Personal Data for us to be able to provide you the requested service or product or for you to participate in the activity. Requested information on the Website marked with an asterisk is mandatory. If you do not provide the requested information, we will not be able to deliver the service or product to you or you cannot participate in the activity. In addition to the information that you may be asked to provide us with in order to participate in such activities / campaigns, we collect certain information when you visit our Website as described below.

Participation in campaigns, prize draws, contests

If you take part in contests or events including prize with purchase promotions (including giveaways, instant wins and online, mobile, social media and app entries), loyalty and reward schemes, activity challenge, sweepstake promotions (including online prize draws, mobile, social media and app entries); sampling and point of sales promotions and geo-targeted activities (including gamification and SMS), (‘Campaign’), depending on the Campaign, you will be asked for your name, email address, home address, telephone number and answers to open questions in order to ‘win’. If needed to send you the prizes per regular mail (for instance, tickets or products), we will also ask for your physical address or we may ask other specific details needed to award your prize to you. We need this information to process your participation and to be able to communicate with you about your prize or to send the prizes to you. All information about your participation in our campaigns, prize draws, and contests will be retained by us for a maximum period of 12 months after the end of the contest, unless otherwise specified in the rules regulating that Campaign. The information will not be used for other purposes if you have not explicitly been informed about these purposes or have been asked for prior consent when it is required.

Information when you contact us

If you have a question, request, or another remark (‘Inquiry’), you can contact us via PrivacyCroatia@heineken.com or via the Contact Form on our Website. Besides the content of your Inquiry, you will be asked to provide your name and email address. We will only use this information to respond to your Inquiry. We will register your requests, questions and our responses and other actions to handle your Inquiry. We will retain this information for 12 months after your Inquiry was closed.

Information about your visit to and use of our Website

We collect certain information when you visit our Website, such as your IP address, which web pages you visit, device category, browser, and type of internet browser, clicks and views. The information about your use of our Website and services enables us to build segments, which are groups of website visitors or customers with a number of common characteristics such as age group, gender or region. We will likely add you to one of our segments. Segments are used by us to customize the Website and, for instance, to change the order of search results or where we place certain offers so you are more likely to see these. We may also use segments to show online advertisements that we think are relevant for you and to send you commercial messages.
We use this Personal Data as it is necessary in our legitimate interests to do so to promote our products and services to our consumers and Website visitors, to enable us to attract more website visitors, to improve the sale of our products and services. We will retain the Personal Data for a maximum of 14 months.

Sending commercial messages

Commercial messages can be sent in multiple ways. You can subscribe to receiving commercial messages (for instance, newsletter), in that case we will use the contact details (such as your email address, social media account or phone number) you have provided to send you our commercial messages. Furthermore, when you purchase a product from us, you will also automatically be added to our customer database and therefore you will receive commercial messages about similar products or services, unless you object to this processing of personal data at the time of your purchase or at a later point. If you no longer wish to receive any commercial messages from us, you can unsubscribe at any time by using the unsubscribe function in each e-mail message.
In the case of an existing business relationship, it is in our legitimate interests to use Personal Data to send our existing customers information about our products. When we are legally required, we will ask for prior consent to send you commercial messages. We will remove your contact details once you have opted-out of receiving commercial messages, unless this is also used and retained for other purposes listed in this Privacy Policy.

Personalized marketing

We may process available information about your online searches and social media activity (clicks and views) such as Twitter, LinkedIn, Google, Facebook, Instagram, your settings on our Website, your customer service requests and contact history can be combined by us. This information enables us to build a profile of your interests and to match this with your other online information (for example by using Facebook Audience Insight services or similar services to the extent allowed under applicable law) in order for us to use different channels for relationship management and marketing of our products and services to you via e-mail, direct mail, social media, telephone or online advertising which may include personalizing website marketing content and offers, in particular when we use data management platforms, so these are tailored to your preferences.
You can always opt-out of receiving our newsletter and object to our use of your Personal Data for direct marketing purposes.
We use this Personal Data based on our legitimate interests to be able to promote our products and services to our customers and website visitors, to maintain the relevance of our brands and reputation and to grow business by serving consumers with advertising relating to our brands. We will ask for prior consent, when we are legally required (for example when we use data for ‘direct marketing’).
We will retain the Personal Data as specified under the relevant purposes for which the Personal Data has been collected (e.g., newsletters, account information, processing orders and payments). The Personal Data shall generally be deleted or anonymized 24 months after your last relevant activity 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.

Maintenance and optimization of our Website

Your Personal Data will also be used for maintenance and analysis of our Website to solve performance issues, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, to improve the availability and user experience of the Website and to secure the Website against fraud. We log all use of our Website.
Our use of your Personal Data for these purposes is necessary in our legitimate interests and the information will be retained for a maximum period of 14 months. The logs of the use of our Website will be deleted within 14 months after creation.

Research activities

We may request you to participate in research activities such as: surveys, pilots, panels, focus groups, and other research activities. Depending on the research activity, we will collect different sets of Personal Data. You will always be informed prior to the research activity what Personal Data we will collect and for what purpose we will collect this Personal data.
Our use of your Personal Data for research activities is necessary in our legitimate interest to ensure we offer a good quality service and products and to further improve or based on your prior specific consent, depending on the type of research activity and which Personal Data we will collect from you. The Personal Data will be retained for a maximum period of 24 months from the conclusion of the research.

Photo and video recordings

Photos and video recordings of public or private events published on the Website, social media, in promotional campaigns or internally inside HEINEKEN Group to promote our products, services and to develop our business may contain Personal Data. We will ask for your consent prior to the processing according to the relevant regulation. The Personal Data in question will be retained for a maximum period of 6 years from taking the photo or video.

Strategic reporting purposes

The Personal Data collected by us is accessed and used by Heineken International B.V. to create aggregated strategic reports with insights which are used to identify opportunities globally and to improve our global brands, products, and services.
Heineken International B.V. uses this information as it is in the legitimate interest of the HEINEKEN Group and all affiliates and subsidiaries to identify opportunities globally and to promote and improve our products and services to our customers and website visitors and to maintain the relevance of our brands and reputation. Your information will be retained for a maximum period of 6 years. We will ask for prior consent, when we are legally required (for example when we use data for ‘direct marketing’).

3. HOW WE SHARE YOUR PERSONAL DATA

As a member of HEINEKEN Group, we share Personal Data and information, including the information we have acquired via ‘cookies’ with Heineken International B.V. for reasons such as strategic reporting and for creating insights and marketing activation as detailed under Item 2 above. We will only share such Personal Data and cookie data when we are allowed to do so by law. This means that, according to applicable regulations, we will ask for your consent, prior to sharing cookie data with or using cookies of our affiliated companies-members of the HEINEKEN Group if such data may only be collected based on consent. When we are allowed to rely on our legitimate interest, we will do so. This is the case when we create aggregated marketing insights or segments.
We may need to share Personal Data with third parties to help us provide services and products to you and to run our Website. These third parties are:
- HEINEKEN group companies for the purpose of storing Personal Data processed via the Website, due to shared IT systems
- service providers where this is needed to provide us with a service and to provide data analytics services
- service providers that help us organize campaigns and promotions
- first and third-party advertising companies
- media agencies for marketing purposes and research purposes
- social media providers
- HEINEKEN group companies 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)
- in case HEINEKEN sells all or some of the assets or shares of a HEINEKEN group company to which Personal Data was transferred to a third party, your Personal Data may be provided to this third party.
These parties may be located in the European Union or other countries in the European Economic Area or elsewhere in the world. When Personal Data is stored by us outside the EEA we will ensure an adequate level of protection of the transferred Data. We require service providers to use appropriate measures for the protection, confidentiality, and security of the Personal Data.
We may also need to provide Personal Data to law enforcement bodies to comply with any legal obligation or court order.

4. SECURITY OF PERSONAL DATA

We will take appropriate technical, physical, and organizational measures to protect the Personal Data collected through the Website from misuse or accidental, unlawful or unauthorized destruction, loss, alteration, disclosure, acquisition or access, that are consistent with applicable privacy and data security laws and regulations. However, no internet-based site can be completely secure, and we cannot be held responsible for unauthorized or unintended access that is beyond our control.
Our Website may contain links to other websites. We are not responsible for the privacy practices, content, or security used by such other websites, which are not governed by this Privacy Policy. We advise you to always carefully read the privacy policies on these other websites.

5. RETENTION OF YOUR PERSONAL DATA

We will retain your Personal Data for as long as legally required or for as long as necessary to provide you with any requested services or for any of the other purposes listed in this Privacy Policy. The specific retention terms are listed in this Privacy Policy for each of the relevant purposes. We will take reasonable steps to destroy or de-identify Personal Data we hold if it is no longer needed for the purposes set out above or after the expiration of the defined retention term.

6. COOKIES

A major part of the information referred to in this Privacy Policy is collected via our use of cookies and similar techniques. Cookies are small text files containing small amounts of information which are downloaded and may be stored on your user device, e.g., your computer, smartphone, or tablet. Techniques we use that may be similar to cookies are tracking pixels, Java scripts, tags and web beacons. These cookies and similar techniques are sometimes necessary to remember your account settings, language and country, but also enable us to measure and analyze your behavior on our Website and for showing you personalized advertisements on our Website or on third party websites. Where required, you will be asked for consent to our use of cookies. To view more information on what cookies we use and how we use them please review our separate Cookie Policy, which is a part of this Privacy Policy and is also available in the footer of this Website.

7. SOCIAL MEDIA

We have profiles/pages and are active on such social media networks as Facebook, Instagram, YouTube, Twitter, LinkedIn. Even though our Website provides links to some of the social media where we are present, that does not set any social media cookies. However, if you click on social media links that may be available on our Website, you will be directed to our respective social media profiles/pages.
Generally, social media cookies could be activated, for example, if content-sharing buttons or embedded videos were used on our Website or if you would somehow interact with our Website via your account on a social media. If you share information from our Website on social media, that information will be visible to visitors of your personal pages on respective social media network, along with your name and preferences.
Social media providers as third parties have their own privacy and cookie policies. We do not control or affect how your data is collected and used by such social media via their own cookies. For these reasons, we advise you to carefully read privacy policies of social media providers as they apply to the processing of your personal data by those parties.

8. CHILDREN’S PRIVACY

The Website is not intended for use by individuals under the age of 18. We do not knowingly collect Personal Data from individuals under the age of 18.

9. YOUR RIGHTS TO ACCESS, RECTIFICATION, DELETION, RESTRICTION, OBJECTION AND DATA PORTABILITY

If the European General Data Protection Regulation applies to the processing of your Personal Data or depending on your local applicable laws and regulations, you have the right to request access to and deletion of your personal data, to request restricted processing or to stop processing or using your Personal Data for profiling, to receive an overview of the personal data that you have provided to us in a structured, commonly used and machine-readable format. Where you have provided consent to our use of your Personal Data, you have the right to withdraw your consent without affecting the lawfulness of our use of your Personal Data prior to the withdrawal. You also have the right to file a complaint with your local data protection authority. In Croatia, that authority is the Croatian Personal Data Protection Agency, Selska cesta 136, 10000 Zagreb (www.azop.hr). Your rights are governed by the applicable national data protection laws and regulations, this Privacy Policy and the Cookie Policy.
Please note that, depending on the use of your choices and rights, you may not be able to use, in whole or in part, our Website services anymore.

10. CONTACT

If you wish to exercise any of your rights listed above, if you have any other questions or comments about this Privacy Policy or about our handling of your Personal Data, please, contact us at PrivacyCroatia@heineken.com or via the contact information available on our Website.
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