What does this privacy notice cover?
This privacy notice provides information about the processing of your personal data when you sign up and use the Heineken Blade Owners Tool (the ‘Blade user platform’). If sign up to become a member we will create a personal profile to also register your devices warranty. This privacy notice explains what personal data we will process, for which purposes, how long we will hold your personal data, how you can access your personal data, and where to go for further information.
We do not intentionally collect data of those under 21 years old. If you are under that age, do not send us your personal data (for example your name, address, and telephone number).
Who is responsible for your personal data?
Sirocco Fz Co as part of the Heineken group (‘we’ or ‘us’) is responsible for your personal data.
What personal data do we process?
If you are registered on the platform we will collect and use the following information about you:
What personal data do we process?
• Full name and Surname
• Cell Phone Number
• Date of Birth
• Visa Status
• Your Order/Transaction Number
Why do we process your personal data?
We process your personal data only if one of the following legal grounds exists:
Where that is necessary to conclude or execute contract that we have with you. For example to be able to register you as a member of the platform and to validate any warranty claim.
Where we have a legitimate business interest to do so. We will always do so only within the boundaries of the data protection laws that apply to the processing or your personal data. For example to help developing new product offerings or services or to improve current products or services or to maintain or promote our relationship with you, to understand consumer and shopping behaviour and trends or to personalise the marketing and promotional activities.
Where we believe it is necessary to use your information to comply with a legal obligation to which we are subject. For example to prove that you are legally permitted to consume, purchase and buy alcoholic beverages (legal drinking age).
Or with your consent. We will always inform you and ask for your consent if we need to do so based under the data protection laws that apply to the processing of your data.
For what purposes do we process your personal data?
We process your personal data for one or more of the following purposes:
To operate the Blade user platform
For example, to create your user profile and provide you with a the user tools to allow you to operate your device correctly, or to provide other product related services (such as notifying in case we need to change terms and conditions related to the product warranty).
We create a personal profile of you based on your registration information to create general group profiles (high level descriptions of different types of consumers) based on aggregated information.
To send you personalised and general marketing communication
One of the benefits of the Blade user platform is that we can show or send you adverts, offers, or other marketing communication for products that we believe you might be interested in. We can do this in collaboration with participating partners. We also can send you information about new Blade services and functionalities.
We decide what communication, adverts or offers we show or send to you using an automated decision making process which takes in account information that you have provided to us as part of your registration to the Blade user platform.
Monitor and analyse trends
Based on aggregate group profile information we can monitor and analyse trends and assess the use and effectiveness of the Blade user platform and who might be interested in the product. We can also use the information to develop new products and services based on a better understanding of consumers’ preferences and needs.
Participate in research activities
We can request you to participate 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. We will provide research activities either with your consent or because we have a legitimate interest, depending on the type and nature of the research activity (participation in a research activity is always voluntary).
We can provide support to you in respect of the Blade user platform and to process and respond to any questions you may have.
How can you opt out of receiving marketing communication?
We will rely on consent to use your information to show you adverts and offers for products we believe you might be interested in. We will rely on consent for sending marketing to you by mail, e mail, text messages and other methods of (electronic) communications from time to time. By signing up for the loyalty program, you consent to receiving such marketing communication, promotional content and processing of your information for genuine business purposes.
Where we rely on consent to use your information, you will have the right to withdraw that consent at any time. For example: you can always opt out from receiving marketing communications and promotional content. We will stop sending you marketing information as soon as possible. Sometimes we cannot process your request immediately, but we will stop sending you information at least within four weeks after we have received your objection.
You may unsubscribe from receiving marketing communication and promotional content and withdraw your data by emailing us at: email@example.com
How long do we keep your information?
We will keep your information as long as is necessary to fulfil the purposes that we describe in this policy and to abide by local regulation.
As a general rule:
1. In line with local regulation the information we collect about you and your use of the Blade user platform (including for example information about you purchase) for a period of 5 years after the moment we have collected the information. You may request to withdraw your information at any point during this period and will subsequently be deleted. Regardless, after this period we will de-identify this information and only use the resulting data on an aggregated level for statistical purposes. For example to for trend analysis or the creation of group profiles (consumer segmentation).
Who will we share your information with?
We are a member of the global Heineken group of companies. We may share your information within the Heineken group (which can be found here: www.heinekencompany.com
) and with the companies operating with the Blade unit and their group companies. If that would be sufficient to achieve the business purposes for which we are sharing data, we will only share data on an aggregated or de-identified level.
We may also share your information with:
• other organisations and service providers that we work with or partner with from time to time including, for example: third party websites, analytics providers and advertising and media companies to enable them to show you adverts or offers which may interest you, including online, and mailing houses so that we can send you information or offers in the post;
• our professional advisors;
• any law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party; and
• any third party that purchases, or to which we transfer, all or substantially all of our assets and business relating to the Blade platform. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your information uses it in a manner that is consistent with this policy.
Transfer of your data to other countries
Your personal data may be transferred to another country. For example if your data is being hosted in a data centre outside your home country, if we are able to remotely access your data from abroad or one of our IT suppliers provides off-premise maintenance and support services from outside your country. Countries to which we transfer personal data may have different privacy standards than the ones in your own country. We will always comply with the requirements –if any- under your own data protection law for the international transfer of data. If we transfer your personal data to a country which does not offer an adequate level of protection we will ensure that we have put in place adequate safeguards to protect your personal data or otherwise ensure that we can transfer your information in a way that complies with data protection law.
Security of your personal information
We will take appropriate, technical, physical and organizational measures to protect your personal information collected through the loyalty program from misuse or accidental, unlawful or unauthorized destruction, loss, alteration, disclosure, acquisition or access, that are consistent with applicable privacy practices and data security laws and regulations.
Where we contract with any service providers, we require the service providers to use appropriate measures to protect the confidentiality and security of your personal information.
You have a number of rights in relation to your personal information. For example: you can decide not to receive marketing information from us, where we rely on your consent for the processing of your data you may withdraw your consent at any time and you can object to some of the ways we use your personal information. Note that some of the choices you make may impact or limit our ability to maintain and manage your Blade platform benefits. Your registration and warranty details may even have to be terminated. We will notify you if such action is necessary. You can request us using the details below at any time:
• To access your personal information (i.e. obtain an overview of your personal data we process).
• To have your personal information corrected, updated rectified or erased or to restrict the processing of your personal information.
• To receive a copy of your personal information in a commonly machine readable format or to have this information transmitted directly to another organisation (if technically possible).
• To lodge a complaint with your local privacy regulator.
To make sure that we do not provide information about you to someone else, we may ask for your identification before we can process your request.
If you have any questions about how we treat your personal data or if you want to exercise your rights in relation to the personal data we process, please contact us at: firstname.lastname@example.org