Privacy Policy | THE SUB®
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Privacy Policy

  1. General

This Privacy Policy applies to our website and mobile app dedicated to THE SUB for consumers in the Italy, available at it.the-sub.com (the "Website"), and located at Tweede Weteringplantsoen 21 H, 1017 ZA Amsterdam (the Netherlands), where we, Online Drinks B.V., collect certain personal information. 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’). Online Drinks B.V. (‘we’ or ‘us’) is the controller of the Personal Data collected and processed.


We respect your privacy, and we are committed to keeping your Personal Data secure and managing it in accordance with our legal responsibilities under applicable data protection laws.

  1. What Personal Data We Collect and How We Use your Personal Data

ou can use the majority of our Website without being required to provide any Personal Data to us. For certain services and purposes of the Website, you need to provide Personal Data to us for us to be able to process your orders or to send commercial messages or other relevant information to you. In addition to the information you are required to provide to us, we collect certain information when you visit our Website. 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.

We have specified the Personal Data we collect, the purposes for which we use the Personal Data and how long we will generally retain your Personal Data:

  • processing your order to be able to process your payment and to deliver the requested product or service to you; We need your name, e-mail address, telephone number (in case we need to communicate to you about your order), postal address of you or the recipient of our services (if different than yourself), your date of birth (as we are legally required to ask for before allowing you to visit our Website), payment information. This is also for our sales administration. The use of this Personal Data is to perform our agreement with you or to comply with legal obligations, such as tax and accounting rules. Our online sales records will be retained by us for 7 years or longer if required by tax or corporate bookkeeping.  

  • Registration and creating an account on our Website. Before you make a purchase, you can create an account and provide us with a log-in name and password (which we need to process your account) and email address, first name/last name, phone number, billing address, birth date (which we will use to process your order or contact you in case of irregularities around your order). You can manage the information in your account yourself and view e.g. which purchases you have made earlier. We will retain your account details for as long as you actively use your account. After 1 year period of inactivity, we will delete your account. You can also request to remove your account via Contact Us. You can also opt to purchase our products as a ‘guest. As a guest, we will save your order in our back end and create a unique customer ID which contains you contact details. If you then make another purchase, we are able to link this order to the same contact details. We do this to avoid duplication of data and to ensure we can fulfil your purchase order. You can also request to remove this data via Contact Us.

  • Customer Services: For answering your questions if you have submitted a question via the Website, for product recalls or other service mails we process your e-mail address or phone number (depending on how you have contacted us) and the question or issue you have raised with us. We register your requests, questions and our responses and other actions to handle your request. Customer Service will retain all information for 1 year after your question or complaint has been solved or the inquiry was closed.

  • Sending commercial emails: The use of your Personal Data is to process your subscription, so to perform our agreement with you, or as it is in our legitimate interests to send our customers information about our products. We will remove your email address once you have opted-out of receiving the newsletter, unless this is also used and retained for other purposes listed in this Privacy Policy. and other marketing information): if you have subscribed for receiving commercial messages, we use the email address you have provided to send you our commercial messages. You will be added automatically to our customer database. If you have ordered one of our products via our Website, we may also send you commercial messages to inform you of our other similar products that we think may be of interest to you. If you no longer wish to receive commercial messages from us, you can unsubscribe at any time by using the unsubscribe function in each commercial message or you can Contact Us

    The use of your Personal Data is to process your subscription, so to perform our agreement with you, or as it is in our legitimate interests to send our customers information about our products. We will remove your email address once you have opted-out of receiving the newsletter, unless this is also used and retained for other purposes listed in this Privacy Policy.

  • Marketing; information about your purchases, your online searches and social media activity (such as Twitter, LinkedIn, Facebook & Instagram) (clicks and views), your settings on our Website, the items in your shopping cart, your customer service requests and contact history can be combined by us. This information enables us to use different channels for relationship management and marketing of our products and services to you via commercial emails, social media, apps or online advertising which may include personalising Website/Email/ App and Social Media content and offers so these are tailored to your preferences. We may also send you information about similar products and services of other HEINEKEN group companies. We measure the effectiveness of our campaigns.

    You can always opt-out of receiving our commercial messages and you can always object to our use of your Personal Data for direct marketing purposes (for more information on how to do this, read the paragraphs 9. and 10. below on your rights).

    We use this Personal Data as it is necessary in our legitimate interests to be able to promote our products and services to our customers and website visitors, to enable us to attract more customers, to improve the sale of our products and services and to finance our Website (via online advertisements). We will retain the Personal Data as specified under the relevant purposes for which the Personal Data have been collected (e.g. commercial messages, account information, processing orders and payments). The Personal Data shall generally be deleted or anonymised within 2 years after your last order 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 as described in the privacy policy.

  • Participate in research activitiesWe also may 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. 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. 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.

  • Allowing you to participate in sweepstakes, contests or other promotions. To administer the sweepstake, contest or other promotion, in which you choose to participate. Some of these promotions have additional rules containing information about how we will use and disclose your Personal Data. We use this information to manage our contractual relationship with you.

  • information about your visit to and use of our Website, apps and commercial messages; We collect certain information when you visit our Website or apps, such as your: IP address, which web pages you visit, the name of your computer, and type of internet browser, clicks and views. We also keep track of how you use our Website and commercial messages: which commercial messages you open, which pages you view and which parts you read, which device you use and when so we can customize, the Website and our commercial messages to your preferences. 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, region or product interest. We will likely add you to one of our segments. Segments are used by us to customize the Website and to e.g. 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 relevant commercial messages to you.

    We use this Personal Data as it is necessary in our legitimate interests to do so to be able to promote our products and services to our customers and website visitors, to enable us to attract more customers, to improve the sale of our products and services and to finance our Website (via online advertisement). We will retain the Personal Data for a maximum of 13 months.

  • Maintenance and optimisation of our Website; Your Personal Data will also be used for maintenance and analysis of our Website to solve performance issues, to improve the availability and to secure the website against fraud (e.g. in case of repeated attempts to log-in or to make a purchase or if the purchase is made where there is non-compliance with our terms and conditions, e.g. by individuals under 18). The analysis also enables us to check whether the online ordering process works efficiently to we can improve, where possible. We log all use of our Website.

    Our use of your Personal Data for these purposes is necessary in our legitimate interests and will be retained for a maximum period of time of 90 days.

    In our commercial emails we link to a preference center. In this preference we are asking questions about your usage of our products. These questions can concern occasions for usage, preferred brands, preferred products or specific information you would like or not like to receive.  You can pro-actively fill this in, to get a better understanding of how you use our product(s). We may use this information for sending you specific offers, discounts or other commercial messages that suit the preferences you have filled in, or exclude you from certain messages. You are not obliged to fill in this information.


  1. How We Share Your Personal Data

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 or to (help us) provide or deliver the service or product ordered by you on the Website (including our third party delivery provider) and to provide data analytics services
  • First and Third party advertising companies
  • Media agencies for marketing purposes and research purposes
  • Social Media Providers, such as Twitter, LinkedIn, Facebook and Instagram
  • Payment service providers that will act as data controller in order to obtain and process payments made by you via the Website;
  • independent debt recovery agencies, solicitors or other agents for the purpose of collecting monies due or outstanding on your account;
  • 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 to protect the confidentiality and security of the Personal Data.

We may also need to provide Personal Data to law enforcement bodies in order to comply with any legal obligation or court order.

  1. 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 100% secure and we cannot be held responsible for unauthorised 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 shall not be governed by this Privacy Policy. We advise you to always carefully read the privacy policies on these other websites.

  1. 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 term 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.

  1. 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 and webforms. These cookies and similar techniques are sometimes necessary to remember your account settings, language and country, but also enable us to measure and analyse your behaviour on our Website and for showing you personalised 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.

  1. Social Media

You may choose to share information on our Website via social media, such as Facebook, LinkedIn, Twitter and Instagram. This means that the information you share, with name and preferences, shall be visible to visitors of your personal pages. We advise you to carefully read the privacy policies of the social media parties as these are applicable to the processing of your Personal Data by these parties.

  1. Children's Privacy

The Website is not intended for use by individuals under the age of 18 (or the applicable legal age for consuming the products in question). We do not knowingly collect Personal Data from individuals under the age of 18.

  1. Your Rights to Access, Rectification, Deletion, Restriction and Data Portability

You have the right to request an overview of your Personal Data processed by or on behalf of us. You have the right to have your Data rectified, deleted or restricted (as appropriate). You can exercise this right by contacting the Customer service. Please note that requests that do not meet the requirements set out by applicable law or HEINEKEN guidelines may be requested to be re-issued or ultimately denied and that certain Personal Data may be exempt from such access, rectification and deletion requests pursuant to applicable data protection laws or other laws and regulations. Please note that we will retain Personal Data where it is legally required for us to do so, which applies e.g. to sales administration.

You have the right to receive the Personal Data that you have provided to us in a structured, commonly used and machine-readable format, and in certain circumstances we will, at your request, transmit your Data to another controller where this is technically feasible.

  1. Your Right to Object

You also have a right, in certain circumstances, to require us to stop processing your Personal Data, but where we have compelling legitimate grounds, we will continue processing your Personal Data. However, you have the right to object to our use of your Personal Data for direct marketing purposes, including profiling, and when you do so, we will accommodate your request.  Where you have provided consent to our use of your Personal Data, you have the right to withdraw your consent without this effecting the lawfulness of our use of this Data before your withdrawal.

  1. Updates

We will keep this Privacy Policy under review and make updates from time to time. Any changes to this Privacy Policy will be posted on our Website page and to the extent reasonably possible, will be communicated to you.

  1. Contact

If you wish to exercise any of your data subject rights, you can contact us at https://secure.theheinekencompany.com/contact-us. Please note that we may request proof of identity. If you have any other question, objection to our use of your Personal Data or a complaint about this Privacy Policy or about our handling of your Personal Data, you can mail Customer Service. You also have the right to file a complaint with your local data protection authority.

 

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