This website is operated by Grolsche Bierbrouwerij Nederland B.V., a member of the Asahi Group Holdings Ltd and its affiliates companies (“Asahi Group”).
We value the careful processing of personal data. This policy applies to our (potential) customers, personnel that work for our customers, website visitors, consumers, distributors, our (potential) suppliers, personnel of such suppliers and contractors. It describes:
- the personal data relating to you that we collect;
- how we use this personal data;
- the legal basis upon which we process it;
- with whom it is shared; and
- how it is stored.
The Policy is comprised of the following Sections:
Section 1: Data collection
Section 2: Use of data
Section 3: Legal basis for use of your personal data
Section 4: Cookies
Section 5: Disclosure of personal data
Section 6: Retention of personal data
Section 7: Your rights
Section 8: Marketing
Section 9: Transfers of data
Section 10: Third party websites
Section 12: Further questions or making a complaint
1. Data collection
We may receive data directly from you. However, we may also receive data about you from third parties such as your employer or recruitment agency, retailers where you are a customer, media agencies, market research companies, our suppliers, group companies, public websites, agencies (including booking agents) and public agencies (including customs officials), which we refer to as "Third Parties " throughout this policy.
We, or Third Parties on our behalf, may collect and use the following personal data (we refer to this as “personal data” throughout this policy):
1.1 - Personal data which you give us (or which we receive from Third Parties).
You or your employer or recruitment agency may give us personal data about yourself by using the online forms provided on our website, completing order forms, setting up an account with us, or by contacting us by phone, e-mail or other means. This includes, for example, when you or your employer provide your personal data to us in order to receive our services. You, or our Third Parties may also give us personal data about you when you are, respectively they are offering or providing services to us.
The personal data which you give us (or which we receive from Third Parties) may include:
(a) Data about you:
- your name;
- your job title;
- company name;
- e-mail address;
- your telephone number;
- account information;
- your company's address;
- your gender;
- your date of birth;
- data provided when you correspond with us;
- any updates to data provided to us; and
- if you attend our sites, CCTV footage.
(b) Data about our website visitors
- if you visit our website, your IP address;
- your user name;
- your age /date of birth;
- your behaviour on our website (for example, the pages that you click on)
- payment details;
- order history; and
(c) Data about the goods or services we provide to you:
- data needed to provide goods or services to you (including data on account opening forms, details of your order, volume of our beers ordered from our appointed Distributor, order history, payment details, delivery address, delivery requirements and restrictions, trade references and tax information);
- the name you give us for personalised products;
- customer services data; and
- customer relationship management and marketing data.
(d) Data about services that we receive from you or your employer (including breweries, bars, wholesalers/distributors, restaurants, media contacts, transport suppliers, warehouses, fulfilment centres, technical support equipment providers and engineers, brand ambassadors and other contractors):
- your photo and video footage if you are a collaborator or brand ambassador, or a potential collaborator or brand ambassador;
- CVs, pitch and tender data; and white paper data;
- supplier due diligence data
- work contact data (phone number, postal address, mailing address, email address);
- visa or work permit documentation;
- emergency contact data;
- work hours (overtime and shift work, hours worked and department standard hours);
- details of compensation, expense claims and bank details;
- court, tribunal and inquiry proceedings (relevant to your work for us); and
- data required to access company systems and applications..
(e) If you use our photo booth at our breweries or events, your photo and the photo timestamp.
(f) If you choose to use social media in order to contact us or find out about our products or services, your profile data (including your preferences and interactions with us on social media and data which you post on message boards which are relevant to our business.
(g) If you attend events, your photograph and event video footage (provided that notice is given to you).
Please note that we need certain types of personal data so that we can provide services to you or so you, or our Third Parties , can provide services to us. If you do not provide us with such personal data, or if you ask us to delete it, you may no longer be able to access our goods and services or provide goods and services to us.
1.2 - Personal data we collect about you or that we obtain from our Third Parties.
(a) If you visit our website, we may automatically collect any of the following data:
- technical data, including the Internet protocol (IP) address used to connect your device to the internet, domain name and country which requests data, the files requested, browser type and version, browser plug-in types and versions, operating system and platform;
- data about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), time and length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and data provided when requesting further service or downloads.
(b) If you contact us on social media, we will collect certain data about you from your social media page and through your interactions with us or with data about our products and services.
(c) If you are a journalist or work for an institution/trade association in our industry, we may collect data about you from public sources.
(d) If you are a customer or a supplier (or a potential customer or supplier) or work for one of them (including as a consultant), we may obtain data about you from your company's website or public sources.
(e) If you are working for us or visiting one of our sites (for example, a brewery) we may also collect personal data about you on CCTV.
2. Use of data
We, or Third Parties acting on our behalf, collect, use and store the personal data listed above for the following reasons:
2.1 - Visiting our website
- to allow you to access and use our website (including to ensure you are of legal drinking age);
- to provide technical support;
- to provide you with the information and services that you request from us;
- to ensure the security of our services, our website;
- to store information about your preferences, and to allow us to customise our websiteaccording to your individual interests;
- to recognise you when you return to our website;
- to enable you to participate in our competitions and promotions;
- to process orders which you place for goods or services from us; and
- for improvement and maintenance of our website and preparing reports or compiling statistics in order to improve our goods and services. Such details will be anonymised as far as is reasonably possible and you will not be identifiable from the data collected.
2.2 - Receiving goods and services from you
- to enable us to receive and manage services from you (including supplier due diligence, payment and expense reporting and financial audits);
- to confirm information on CVs and performance reference checks, to assess you or your employer's suitability to work for us;
2.3 - Providing goods and services to you
- to provide relevant goods or services to you or your employer (including, to confirm and process orders, for administration of your account with us, customer loans, tax and export, billing and debt collection purposes and the collection of bottles (where applicable));
- to deal with any enquiries or issues you have about our goods and services, including any questions you may have about how we collect, store and use your personal data, or any requests made by you for a copy of the data we hold about you. If we do not have a contract with you, we may process your personal data for these purposes where it is in our legitimate interests for customer services purposes;
- to send you certain communications (including by email or post) about our goods and services such as service announcements and administrative messages (for example, setting out changes to our terms and conditions and keeping you informed about our fees and charges);
- to allow you to attend our events or participate in competitions and to send you photos that you have permitted us to take of you;
- to carry out statistical analysis and market research; and
- if you have consented or, otherwise, if it is in our legitimate interests, for business development and marketing purposes, to contact you (including by email or post) with information about our products and services which either you request, or which we feel will be of interest to you (including newsletters), but only, if required by law if you have consented to this.
2.4 - For internal commercial reasons (legitimate interest), for instance a database which contains data of all outlets in the Netherlands, including possible potential customers in the (near) future.
2.5 - For the purposes of fraud protection and credit risk reduction.
2.6 - For internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies.
2.7 - To comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so.
2.8 - To establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.
2.9 - If you visit one of our sites (including a brewery), for CCTV monitoring and ensuring the security of our staff and visitors, and our and their property.
2.10 - If you contact us on social media, to interact, as well to monitor your interactions with us and our brand online, where it is in our legitimate interests to do so for market research and for planning future marketing campaigns.
2.11 - If we use your photograph or video footage from an event, to amplify the event to a broader audience and for internal presentation purposes, where it is in our legitimate interests for marketing and business development purposes or where we have your consent.
2.12 - If you are a journalist, where it is in our legitimate interests to contact you to invite you to write a news article about our products and services; to invite you to events, send you promotional material and for press releases.
3. Legal basis for use of your personal data
- our use of your personal data is necessary for complying with our legal obligations (for example, providing information to HMRC); or
- where neither (1) nor (2) apply, use of your personal data is necessary for our legitimate interests (including Asahi Group) or the legitimate interests of others for example, to ensure the security of our website. Our legitimate interests are to:
- run, grow and develop our business;
- operate our website;
- select appropriately skilled and qualified suppliers;
- ensure a safe working environment for our staff and visitors;
- marketing, market research and business development;
- provide goods and services to our customers, make and receive payment, provide customer services and to know the customer that we are providing services to;
- place, track and ensure fulfilment of orders with our suppliers; and
- for internal group administrative purposes of Asahi Group, as described in section 5.1 below.
3.2 - We may use your special categories of data where - if none of the legal basis described under a), b) or c) is applicable - you have provided your consent (which you may withdraw at any time after giving it, as described below).
3.3 - In the future, other use of other personal data may be subject to your consent (which can be withdrawn at any time after giving it, as described below)..
3.4 - If we rely on your consent for us to use your personal data in a particular way, but you later change your mind, you may withdraw your consent by contacting us at email@example.com
and we will stop doing so.
5. Disclosure of personal data
5.1 - We may share your personal data with any company that is a member of our group which includes our ultimate parent company based in Japan where it is required for our legitimate interests to do so for internal administrative purposes (for example, ensuring consistent and coherent delivery of services to our customers, corporate strategy, compliance, auditing and monitoring, research and development and quality assurance). We may also share your personal data with our group where they provide products and services to us as “processors”, such as information technology systems.
5.2 We will share your personal data with the following categories of third parties:
- our service providers and sub-contractors, including but not limited to payment processors, suppliers of technical and support services, insurers, logistic providers, and cloud service providers;
- your employer or recruitment agency;
- retailers and wholesalers, where you are a customer, provided such is to perform our obligations under any contract with you;
- public agencies (including customs officials);
- companies that assist us in our marketing, advertising and promotional activities; and
- analytics and search engine providers that assist us in the improvement and optimisation of our website and our software apps.
5.3 - We will, if this is necessary and only on a case by case basis, also disclose your personal data to third parties:
- where it is in our (including Asahi Group) legitimate interests to do so to run, grow and develop our business:
- if we sell or buy any business or assets, we may disclose your personal data to the seller or buyer of such business or assets;
- if substantially all of our or any of our affiliated companies' assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
- in order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
- to protect the rights, property, or safety of Asahi Group our staff, our customers or other persons.
5.4 - We may also disclose and use anonymised, aggregated reporting and statistics about users of our website and apps or our goods and services and from interactions with us and our brands on social media for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
5.5 - Save as expressly detailed above in this article, we will never share, sell or rent any of your personal data to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal data in a particular way, but later change your mind, you should contact us and we will stop doing so.
6. Retention of personal data
We keep your personal data for no longer than necessary for the purposes for which the personal data are processed. The length of time we retain personal data for depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
7. Your rights
7.1 - You have certain rights in relation to your personal data. If you would like further information in relation to these or would like to exercise any of them, please contact us by email at firstname.lastname@example.org at any time. You have the right to request that we:
- provide access to any personal data we hold about you;
- update any of your personal data which is out of date or incorrect;
- delete any personal data which we are holding about you;
- restrict the way that we process your personal data;
- prevent the processing of your personal data for direct-marketing purposes;
- provide you with a copy of any personal data which we hold about you; or
- consider any valid objections which you have to our use of your personal data.
7.2 - We will consider all such requests and provide our response within a reasonable period (and in any event any time period required by applicable law). Please note, however, that certain personal data may be exempt from such requests in certain circumstances.
7.3 - If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
8.1 - We may collect and use your personal data to send you certain marketing communications (including electronic marketing communications to existing customers) if it is in our legitimate interests to do so for marketing and business development purposes.
8.2 - However, we will always obtain your consent to direct marketing communications where we are required to do so by law.
8.3 - If you wish to stop receiving marketing communications, you can contact us by email at email@example.com at any time or by calling our free telephone number 0800 7770888 during business hours, and we will stop doing so.
9. Transfers of personal data
9.1 - The personal data may be used, stored and/or accessed by staff operating outside the EEA working for us, other members of our group or Third Parties . This may be for the purposes listed in section 2 above, including but not limited to the provision of our services to you or your employer, the receipt of services from you or any of our Third Parties, the processing of transactions and/or the provision of support services. Further details on to whom your personal data may be disclosed are set out in section 5 above.
- in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or
- in the case of entities based in other countries outside the EEA (including Japan), entering into European Commission approved standard contractual arrangements with them.
9.3 - Further details on the steps we take to protect your personal data, in these cases is available from us on request by contacting us by email at firstname.lastname@example.org
at any time.
10. Third party websites
Our website and social media pages may, from time to time, contain links to websites operated by third parties including partner networks and our group companies. Please note that we cannot be responsible for personal data about you that is collected and stored by other types of third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal data to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.
12. Further questions or making a complaint
12.1 - If you have any queries or complaints about our collection, use or storage of your personal data, or if you wish to exercise any of your rights in relation to your personal data, please contact email@example.com. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal data.
12.2 - You may also make a complaint to the data protection authority in the European Union country where we are based, which is the “Autoriteit Persoonsgegevens” in the Netherlands, or where we process personal data that relates to offering goods or service to you in the European Union. Alternatively you may seek a remedy through local courts if you believe your rights have been breached.