EAZLE PRIVACY POLICYGENERALThis Privacy Policy applies to our eazle eCommerce platform dedicated to HEINEKEN International B.V. (‘HEINEKEN’), 2e Weteringplantsoen 21, 1017 ZD Amsterdam, Netherlands (the “eazle Platform”) where HEINEKEN (including its Subsidiaries and/or Affiliates: ‘we’ or
‘us’) will 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 eazle Platform (‘Personal Data’). We are the controller
of the Personal Data collected and processed. However, where processing is undertaken for
the purpose of globally strategic reporting, HEINEKEN is a separate data controller of your
Personal Data.
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.WHAT PERSONAL DATA WE COLLECT AND HOW WE USE YOUR PERSONAL DATAWe receive or collect Personal Data, as described below, when you use the services of the
eazle Platform. If you do not want us to collect and process your Personal Data, you may not
be able to use some of the eazle Platform’s services.
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:
1. Registration and account creation Before you can make use of the eazle platform, you will be asked to 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, billing address (which we will use to process your order). Additionally, we require you to provide your date of birth when visiting the eazle Platform as we are legally required to ask for before allowing you to visit the eazle Platform. You can manage the information in your account yourself and view e.g., which purchases you have made earlier. The processing of your Personal Data when you create an account is processing is based on the performance of our contract with you. We will retain your account details for as long as you actively use your account. After a period of inactivity, we will delete your account. If you wish to delete your account, please contact info@eazle.com.
2. Order and delivery processing We need your name, e-mail address, telephone number (in case we or the distributor need to communicate to you about your order), delivery and billing address of you or the recipient of our services (if different than yourself), and bank account and card payment details and details about payments as well as product and services purchased from us. This information is also used for our sales administration. The processing of your Personal Data for order and delivery processing is based on the performance of our contract with you, or to comply with legal obligations, such as tax and accounting rules. Our online sales records will be retained by us for a period required by tax or corporate bookkeeping.
3. Customer services For answering your questions and handling complaints if you have submitted a question via the eazle Platform. 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 until your question or complaint has been solved or the inquiry was closed, except where we are legally required to retain the Personal Data or when it is kept for any of the other purposes. The processing of your Personal Data for customer services is based on the performance of our contract with you, or on our legitimate interest, when we create insights and improvements, or our services based on the issues or questions that you have raised with us.
4. Maintenance and optimisation We collect certain information when you visit the eazle Platform, such as your IP address, the web pages you visit within the eazle Platform, the type of your internet browser, and clicks and views. Some if this information is Personal Data which will be used for maintenance and analysis of the eazle Platform to solve performance issues, to improve the availability and to secure the eazle Platform 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. Our use of your Personal Data for these purposes is necessary in our legitimate interests.
5. Research activities We 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 categories 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. 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.
6. Newsletters If you have subscribed for the newsletter, we use the email address you have provided to send you the newsletter. If you have ordered one of the products via the eazle Platform, we can also send you newsletters to inform you of other similar products that we think may be of interest to you. If you no longer wish to receive any e-mails from us, you can unsubscribe at any time by using the unsubscribe function in each e-mail message or you can contact us at info@eazle.com. The use of your Personal Data to send newsletters is based on your consent, or our legitimate interest.
7. Direct marketing, promotions and loyalty Information about your purchases, your online searches within the eazle Platform (clicks and views), your settings on the eazle Platform, 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 (personalised) marketing of our products and services to you via e-mail (i.e., newsletters) or online advertising. This includes personalising eazle Platform content and offers so these are tailored to your preferences. In addition, we use this information for offering you with Reward points in the eazle club section of the eazle Platform. Depending on the type and volume of purchase you make, you will be awarded Reward Points you can use to redeem products of your choice. Please refer to the eazle Terms & Conditions for more information. You can always opt-out of receiving our newsletter or direct mail and you can always object to our use of your Personal Data for direct marketing or loyalty purposes. We use your Personal Data for marketing purposes based on your consent, or our legitimate interest.
8. Information about your visit to and use of eazle Platform Using cookies and similar technologies, we collect certain information when you visit the eazle Platform, 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 newsletter, which pages you view and which parts you read so we can customize the newsletter to your preferences. The information about your use of the eazle Platform and services enables us to build segments, which are groups of website visitors or customers with several 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 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 online advertisements that we think are relevant for 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.
9. Strategic reporting purposes. All the Personal Data collected by us is accessed and used by HEINEKEN to create aggregated strategic reports, which are used to identify opportunities globally and improve our products and services. HEINEKEN and we use this information based on a joint-legitimate interest to identify opportunities globally and improve our products and services.We do not 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 genetic and biometric data), nor do we process any information about criminal convictions and offences.HOW WE SHARE YOUR PERSONAL DATAWe share your Personal Data with third parties, with the purpose to help us provide services and products to you, and to run the eazle Platform. These third parties and purposes are: o HEINEKEN group companies for the purpose of storing Personal Data processed via the eazle Platform, due to shared IT systems. o Credit Reference Agencies (“CRAs”). When you apply to become an eazle Platform customer, 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 can also share your information with other interested parties for credit reporting purposes. o Independent debt recovery agencies other agents for the purpose of collecting monies due or outstanding on your account. o Couriers, hauliers, and other service companies necessary for providing you with goods or services you have requested. o HEINEKEN for strategic reporting purposes, for which HEINEKEN acts as independent controller. o HEINEKEN for analytical and segmentation purposes, for which HEINEKEN acts as independent controller. o Service providers who provide us with a service that enable the digital services on the eazle Platform and provide data analytics services. In the event HEINEKEN sells all or some of the assets or shares of a HEINEKEN group company, your Personal Data can be provided to this third party. In addition, we can use, disclose, or transfer your information to a HEINEKEN group company 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). The products you order are distributed via one of our distributors. This distributor will gain similar access to your (personal) data, as provided to HEINEKEN. Your distributor will act as a controller in relation to the (personal) data that the distributor processes. If you want to contact your distributor, please find their contact details on the eazle Platform. These parties may be located in in the European Union or other countries in the European Economic Area or elsewhere in the world. Personal Data is stored by us inside the EEA and we will ensure an adequate level of protection. 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 to comply with any legal obligation or court order.SECURITYWe have put in place appropriate 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 you should also note that 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, so please take care to protect this information. The eazle Platform may 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 notice of every website you visit and third-party service/application that you use.RETENTION OF PERSONAL DATAWe 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.COOKIESPart of the information, which could constitute Personal Data, referred to in this Privacy Policy is collected via our use of cookies and similar techniques.LEGAL DRINKING AGEThe eazle Platform is not intended for use by individuals under the age of 18 (or the applicable legal drinking age for consuming the products in question). We do not knowingly collect Personal Data from individuals under the age of 18.YOUR CHOICES AND RIGHTSIf your Personal Data is or has been subject to the European GDPR (General Data Protection Regulation) or to the extent applicable under your local law, you have the right to request access to and deletion of your Personal Data, to object, to request restricted processing, to receive an overview of the Personal Data that you have provided to us in a structured, commonly used and machine-readable format. You also have the right to file a complaint with your local data protection authority. All your rights are subject to applicable data protection laws and other relevant laws and regulations, to the HEINEKEN Privacy Procedures and other HEINEKEN guidelines. However, you always have the right to object to our use of your Personal Data for direct marketing communications, 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. Please note that if you make use of (some of) your choices and rights, you may not be able to use, in whole or in part, of the eazle Platform services anymore.UPDATESWe will keep this Privacy Policy under review and make updates from time to time. Any changes to this Privacy Policy will be posted on the eazle Platform page and to the extent reasonably possible, will be communicated to you.CONTACTIf you wish to exercise any of your rights listed above, you can contact us at info@eazle.com. Please note that we reserve the right to 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 e-mail info@eazle.com. HEINEKEN is the controller for Personal Data processed for strategic overviews. If you have any question, objection to our use of your Personal Data or want to make use of any of your Personal Data rights or file a complaint about this use of Personal Data or about the handling of your Personal Data, please contact us via info@eazle.com with a data privacy request. The most recent version of this privacy notice is dated: 2 October 2024
1. Registration and account creation Before you can make use of the eazle platform, you will be asked to 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, billing address (which we will use to process your order). Additionally, we require you to provide your date of birth when visiting the eazle Platform as we are legally required to ask for before allowing you to visit the eazle Platform. You can manage the information in your account yourself and view e.g., which purchases you have made earlier. The processing of your Personal Data when you create an account is processing is based on the performance of our contract with you. We will retain your account details for as long as you actively use your account. After a period of inactivity, we will delete your account. If you wish to delete your account, please contact info@eazle.com.
2. Order and delivery processing We need your name, e-mail address, telephone number (in case we or the distributor need to communicate to you about your order), delivery and billing address of you or the recipient of our services (if different than yourself), and bank account and card payment details and details about payments as well as product and services purchased from us. This information is also used for our sales administration. The processing of your Personal Data for order and delivery processing is based on the performance of our contract with you, or to comply with legal obligations, such as tax and accounting rules. Our online sales records will be retained by us for a period required by tax or corporate bookkeeping.
3. Customer services For answering your questions and handling complaints if you have submitted a question via the eazle Platform. 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 until your question or complaint has been solved or the inquiry was closed, except where we are legally required to retain the Personal Data or when it is kept for any of the other purposes. The processing of your Personal Data for customer services is based on the performance of our contract with you, or on our legitimate interest, when we create insights and improvements, or our services based on the issues or questions that you have raised with us.
4. Maintenance and optimisation We collect certain information when you visit the eazle Platform, such as your IP address, the web pages you visit within the eazle Platform, the type of your internet browser, and clicks and views. Some if this information is Personal Data which will be used for maintenance and analysis of the eazle Platform to solve performance issues, to improve the availability and to secure the eazle Platform 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. Our use of your Personal Data for these purposes is necessary in our legitimate interests.
5. Research activities We 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 categories 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. 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.
6. Newsletters If you have subscribed for the newsletter, we use the email address you have provided to send you the newsletter. If you have ordered one of the products via the eazle Platform, we can also send you newsletters to inform you of other similar products that we think may be of interest to you. If you no longer wish to receive any e-mails from us, you can unsubscribe at any time by using the unsubscribe function in each e-mail message or you can contact us at info@eazle.com. The use of your Personal Data to send newsletters is based on your consent, or our legitimate interest.
7. Direct marketing, promotions and loyalty Information about your purchases, your online searches within the eazle Platform (clicks and views), your settings on the eazle Platform, 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 (personalised) marketing of our products and services to you via e-mail (i.e., newsletters) or online advertising. This includes personalising eazle Platform content and offers so these are tailored to your preferences. In addition, we use this information for offering you with Reward points in the eazle club section of the eazle Platform. Depending on the type and volume of purchase you make, you will be awarded Reward Points you can use to redeem products of your choice. Please refer to the eazle Terms & Conditions for more information. You can always opt-out of receiving our newsletter or direct mail and you can always object to our use of your Personal Data for direct marketing or loyalty purposes. We use your Personal Data for marketing purposes based on your consent, or our legitimate interest.
8. Information about your visit to and use of eazle Platform Using cookies and similar technologies, we collect certain information when you visit the eazle Platform, 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 newsletter, which pages you view and which parts you read so we can customize the newsletter to your preferences. The information about your use of the eazle Platform and services enables us to build segments, which are groups of website visitors or customers with several 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 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 online advertisements that we think are relevant for 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.
9. Strategic reporting purposes. All the Personal Data collected by us is accessed and used by HEINEKEN to create aggregated strategic reports, which are used to identify opportunities globally and improve our products and services. HEINEKEN and we use this information based on a joint-legitimate interest to identify opportunities globally and improve our products and services.We do not 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 genetic and biometric data), nor do we process any information about criminal convictions and offences.HOW WE SHARE YOUR PERSONAL DATAWe share your Personal Data with third parties, with the purpose to help us provide services and products to you, and to run the eazle Platform. These third parties and purposes are: o HEINEKEN group companies for the purpose of storing Personal Data processed via the eazle Platform, due to shared IT systems. o Credit Reference Agencies (“CRAs”). When you apply to become an eazle Platform customer, 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 can also share your information with other interested parties for credit reporting purposes. o Independent debt recovery agencies other agents for the purpose of collecting monies due or outstanding on your account. o Couriers, hauliers, and other service companies necessary for providing you with goods or services you have requested. o HEINEKEN for strategic reporting purposes, for which HEINEKEN acts as independent controller. o HEINEKEN for analytical and segmentation purposes, for which HEINEKEN acts as independent controller. o Service providers who provide us with a service that enable the digital services on the eazle Platform and provide data analytics services. In the event HEINEKEN sells all or some of the assets or shares of a HEINEKEN group company, your Personal Data can be provided to this third party. In addition, we can use, disclose, or transfer your information to a HEINEKEN group company 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). The products you order are distributed via one of our distributors. This distributor will gain similar access to your (personal) data, as provided to HEINEKEN. Your distributor will act as a controller in relation to the (personal) data that the distributor processes. If you want to contact your distributor, please find their contact details on the eazle Platform. These parties may be located in in the European Union or other countries in the European Economic Area or elsewhere in the world. Personal Data is stored by us inside the EEA and we will ensure an adequate level of protection. 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 to comply with any legal obligation or court order.SECURITYWe have put in place appropriate 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 you should also note that 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, so please take care to protect this information. The eazle Platform may 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 notice of every website you visit and third-party service/application that you use.RETENTION OF PERSONAL DATAWe 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.COOKIESPart of the information, which could constitute Personal Data, referred to in this Privacy Policy is collected via our use of cookies and similar techniques.LEGAL DRINKING AGEThe eazle Platform is not intended for use by individuals under the age of 18 (or the applicable legal drinking age for consuming the products in question). We do not knowingly collect Personal Data from individuals under the age of 18.YOUR CHOICES AND RIGHTSIf your Personal Data is or has been subject to the European GDPR (General Data Protection Regulation) or to the extent applicable under your local law, you have the right to request access to and deletion of your Personal Data, to object, to request restricted processing, to receive an overview of the Personal Data that you have provided to us in a structured, commonly used and machine-readable format. You also have the right to file a complaint with your local data protection authority. All your rights are subject to applicable data protection laws and other relevant laws and regulations, to the HEINEKEN Privacy Procedures and other HEINEKEN guidelines. However, you always have the right to object to our use of your Personal Data for direct marketing communications, 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. Please note that if you make use of (some of) your choices and rights, you may not be able to use, in whole or in part, of the eazle Platform services anymore.UPDATESWe will keep this Privacy Policy under review and make updates from time to time. Any changes to this Privacy Policy will be posted on the eazle Platform page and to the extent reasonably possible, will be communicated to you.CONTACTIf you wish to exercise any of your rights listed above, you can contact us at info@eazle.com. Please note that we reserve the right to 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 e-mail info@eazle.com. HEINEKEN is the controller for Personal Data processed for strategic overviews. If you have any question, objection to our use of your Personal Data or want to make use of any of your Personal Data rights or file a complaint about this use of Personal Data or about the handling of your Personal Data, please contact us via info@eazle.com with a data privacy request. The most recent version of this privacy notice is dated: 2 October 2024