LAST UPDATED: January 1, 2020

Heineken USA Incorporated (“HEINEKEN,” “we” or “us”) wants you to know that we respect your privacy and recognize your desire to safeguard your personal information. This Privacy Policy describes our practices in connection with information that we collect through websites, software, social media sites and applications controlled by HEINEKEN, as well as through HTML-formatted email messages that we send to you that link to this Privacy Policy (collectively, the “Services”). The section below entitled “California Privacy Rights” describes our practices with respect to the personal information we collect, online and offline, from California residents. If you are a California resident and our past, current, or prospective employee or contractor or an emergency contact or benefits beneficiary of any such employee or contractor, please click here for our privacy notice applicable to you.

The Services are intended for people who are 21 years of age or older. If someone under the legal drinking age has provided HEINEKEN with personal information by obtaining access to the Services in violation of our access restrictions, we request that the parent or legal guardian of that person contact HEINEKEN so we can remove the information from our records.

Personal Information

Personal Information We May Collect

“Personal Information” is information that identifies you as an individual or
relates to an identifiable person, including, for example, your:

• Name
• Email address
• Postal address
• Telephone number
• Credit and debit card number
• Social media account ID

How We May Collect Personal Information

We may collect Personal Information in a variety of ways, including:

• Through the Services: We may collect Personal Information through the Services, such as when you enter our website via our age gate.
• From Other Sources: We may receive your Personal Information from other online and offline sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties. For example, if you elect to connect your social media account to your website account, certain Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your profile or your friends’ profiles.

How We May Use Personal Information

We may use Personal Information:

• To respond to your inquiries, fulfill your requests and process your transactions, and to provide you with related customer service.
• To send administrative information to you, such as information regarding the Services and changes to our terms, conditions and policies.
• To send you marketing communications that we believe may be of interest to you.
• To personalize your experience on the Services by presenting products and offers tailored to you.
• To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information. We suggest that you read any such rules carefully.
• To facilitate social sharing functionality.
• For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

How Personal Information May Be Disclosed

Your Personal Information may be disclosed:

• To our affiliates, for the purposes described in this Privacy Policy.
• To our third party service providers who provide services such as website hosting, data management and analysis, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
• To third parties that co-sponsor or co-brand activities with HEINEKEN, including to permit them to send you marketing communications.
• To third-party sponsors and administrators of sweepstakes, contests and similar promotions.
• By you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials that are visible to other users and/or the general public (“Public Postings”) via the Services. Please note that any information you post or disclose via Public Postings will become public information. We urge you to be very careful when deciding to publicly disclose any information on the Services.
• To your friends associated with your social media account, to other users of the Services and to your social media account provider, in connection with your social sharing activity, such as if you connect your social media account to your Services account or log into your Services. account from your social media account. By connecting your Services account and your social media account, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s privacy policy. If you do not want your Personal Information shared with other users or with your social media account provider, please do not connect your social media account with your use of the Services and do not participate in social sharing on the Services.
• To a third party 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).

Other Uses and Disclosures

We also may use and disclose your Personal Information as we believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence;

(b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

Other Information

Other Information We May Collect

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an individual, such as:

• Browser and device information
• App usage data
• Information collected through cookies, pixel tags, web beacons and other technologies
• IP address
• Location information
• Demographic information and other information provided by you
• Aggregated information

If we are required to treat Other Information as Personal Information under applicable law, then we may use it for the purposes for which we use and disclose Personal Information as detailed in this Policy.

How We May Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:

• Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
• Through your use of an App: When you download and use a HEINEKEN App, we and our service providers may track and collect app usage data, such as the date and time the app on your device accesses our servers and what information and files have been downloaded to the app.
• Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Services and to recognize your computer in order to facilitate your use of the Services. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies to track responses to our online advertisements.

  If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer, and you may need to enter your birthday every time you visit. You also may not receive advertising or other offers from us that are relevant to your interests and needs.

• Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used in connection with some Services to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Services and response rates.
• Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• Using Adobe Flash technology (including Flash Local Shared Objects (“Flash LSOs”)) and other similar technologies: We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Services. If you do not want Flash LSOs stored on your computer, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to as “information” on the Macromedia site), how to prevent Flash LSOs from being placed on your computer without your being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time). Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications.
• IP Address: Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your location from your IP address.
• Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content.
• From you: Information, such as your preferences or demographic information is collected when you voluntarily provide it.
• By aggregating information: Aggregated Personal Information does not personally identify you or any other user of the Services (for example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code).

How We May Use and Disclose Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

Do Not Track Signals

Some web browsers have settings that include “do not track signals.” The Services are not currently engineered to respond to those signals.

Third Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to them in connection with the Services.

Our Advertising

We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services, based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about these practices, and to learn how to opt out of them in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://www.networkadvertising.org/choices/ and http://www.aboutads.info/. You may download the AppChoices app at http://youradchoices.com/appchoices to opt out in mobile apps.

Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the "Contacting Us" section below.

Choices and Access

You may opt out of receiving marketing emails from us by following the instructions contained in each such email. In addition, certain Services may give you the ability to opt out through your account settings. We will try to comply with your request as soon as reasonably practicable. Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.

If you would like to request to review, correct, update, suppress or delete Personal Information that you have previously provided to us, you may write to us at corporaterelations@heinekenusa.com. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

If you are a resident of California, please see the section entitled “California Privacy Rights,” below, for more information about the rights you have under California law.

Cross-Border Transfer

The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information may be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

Sensitive Information

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics or criminal background) on or through the Services or otherwise to us.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time. The “LAST UPDATED” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.

Contacting Us

If you have any questions about this Privacy Policy, please contact us at corporaterelations@heinekenusa.com. Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

California Privacy Rights

If you are a California resident and our past, current, or prospective employee or contractor or an emergency contact or benefits beneficiary of any such employee or contractor, please click here for our privacy notice applicable to you.

This section provides information for California residents in connection with the California Consumer Privacy Act of 2018 (“CCPA”). Under the CCPA, and for purposes of this section, “Personal Information” generally means information that identifies, relates to, or describes a California resident or household and includes the categories listed below. Below are details about the categories of Personal Information of California residents that we have collected or disclosed during the last 12 months.

Categories of Personal Information Collected: We collected the following categories of Personal Information:

1. Identifiers, such as name, IP address, email address, online identifiers, and government-issued ID numbers;
2. Personal information, as defined in the California customer records law, such as contact and financial information;
3. Characteristics of protected classifications under California or federal law, such as age, gender, and marital status;
4. Commercial information, such as transaction information and purchase history;
5. Internet or network activity information, such as browsing history and interactions with our websites and applications;
6. Geolocation data, such as device location;
7. Audio, electronic, visual, and similar information, such as call and video recordings;
8. Professional or employment-related information, such as work history and prior employer;
9. Non-public education information; and
10. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Depending on a California consumer’s particular interactions and relationship with us, we may not have collected each of the above categories about each consumer.

Sources of Personal Information. We collect this Personal Information directly from California residents themselves, as well as from other online and offline sources, such as public databases, joint marketing partners, and social media platforms.

Purposes. We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, to: develop, improve, and maintain our products and services; personalize, advertise, market, and provide our products and services and related customer service; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.

Disclosures of Personal Information. We disclosed the following Personal Information to our affiliates, service providers, and joint-marketing partners for our operational business purposes:

1. Identifiers, such as name, IP address, email address, online identifiers, and government-issued ID numbers;
2. Personal information, as defined in the California customer records law, such as contact and financial information;
3. Characteristics of protected classifications under California or federal law, such as age, gender, and marital status;
4. Commercial information, such as transaction information and purchase history;
5. Internet or network activity information, such as browsing history and interactions with our websites and applications;
6. Geolocation data, such as device location;
7. Audio, electronic, visual, and similar information, such as call and video recordings;
8. Professional or employment-related information, such as work history and prior employer;
9. Non-public education information; and
10. Inferences drawn from any of the Personal Information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

Depending on a California consumer’s particular interactions and relationship with us, we may not have disclosed each of the above categories about each consumer.

“Sales” of Personal Information. The CCPA defines a “sale” as the disclosure of Personal Information in exchange for monetary or other valuable consideration. We have not sold our customer list or similar personal information for payment, but we may have engaged in certain types of online interest-based advertising that may be deemed a “sale” for purposes of the CCPA. We may have “sold” the following categories of Personal Information:

1. Identifiers, such as name, IP address, email address, online identifiers, and government-issued ID numbers;
2. Personal information, as defined in the California customer records law, such as contact and financial information;
3. Characteristics of protected classifications under California or federal law, such as age, gender, and marital status; and
4. Internet or network activity information, such as browsing history and interactions with our websites and applications.

Depending on a California consumer’s particular interactions and relationship with us, we may not have “sold” each of the above categories about each consumer. The CCPA definition of “sale” does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.

If you are a California resident, you have the following rights:

(1) Right to Know. You have the right to request that we disclose to you the following information covering the 12 months preceding your request:

• The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
• The specific pieces of Personal Information we collected about you;
• The business or commercial purpose for collecting or selling Personal Information about you;
• The categories of Personal Information about you that we sold and the categories of third parties to whom we sold such Personal Information; and
• The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information.

(2) Right to Request Deletion. You have the right to request that we delete Personal Information we collected from you.

To make a request for the disclosures or deletion described above, please click here or call us at 1-877-522-5001. We will respond to your request consistent with applicable law.

(3) Right to Opt Out of Sale. You may opt out of future “sale” of Personal Information about you by clicking here.

(4) Right to Be Free from Discrimination. You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.

(5) Right to Request Information About Our Information Sharing.

Under California Civil Code section 1798.83, California residents have the right to request and receive from HEINEKEN, once a year, free of charge, information about the personal information we have disclosed (if any) to third parties for their marketing purposes during the previous calendar year, and a description of the categories of personal information shared. To make such a request, please send an email to corporaterelations@heinekenusa.com, including the phrase “California Privacy Request” in the subject line, and provide HEINEKEN with your name, postal address and email address.