Heineken International B.V., located at Tweede Weteringplantsoen 21, 1017ZD, Amsterdam, the Netherlands (“Heineken” or “we” or “us”) is the controller of the processing of all personal data collected when you participate in the Star of the Match activation (‘the Game’) – a Game through which you can indicate which player you think will become the Star of the Match for any of the matches in the Euro2020 championship for soccer. The Game is accessible on www.heineken.com/starofthematch (‘the Website’).
We do not knowingly collect Personal Data relating to children and have age verification processes on our Game. Further, we do not market our products or services to anyone under the age of 18.
2. What Personal Data We Collect and How We Use it
If you wish to use the Game, you must provide us with your first name, email address, date of birth and country of residence. In addition to the information you are required to provide to us in order to participate in activities/campaign, we collect certain information when you use our Game.
2.1. Information when you contact us and processing your entry
We need your first name, email address to communicate with you about your participation in the Game, to process your entry in the Game and to notify you. We use your country of residence to check if you are eligible for certain prizes - prizes may be different per country. We also use your country of residence to verify with which local Heineken organisation to share your personal data, in case you have consented to this.
If you have a question or remark about our Game, you can contact us at firstname.lastname@example.org. We will register your requests, questions, our responses, and other actions to handle your request. We will only use this information to respond to your question. We retain this information for 6 months after the end of the Game or until your question or complaint has been solved or the inquiry was closed. The use of this Personal Data is to perform our agreement with you.
2.2. Information about your use of our Game
To the extent necessary for our legitimate interests and, if provided, to the extent allowed based on your optional consent, we collect certain information when you use our Game, such as your device category, the country that you are in, based on the IP address when you first log in to the Game. The information about your use of our Game, and other services, enables us to build segments that are groups of Game or website visitors or customers with some common characteristics such as age group, gender, or region. We will likely add you to one of our segments. These segments are used to target you with online advertisements and commercial messages that we think are relevant for you.
We use Personal Data as it is necessary in our legitimate interests to promote our products and services to our consumers, website visitors and Game users, to enable us to attract more consumers, to improve the sale of our products and services. We will retain the Personal Data for a maximum of 24 months.
2.3. Receiving emails and newsletters
If you are participating in our Game, we may send you e-mails to inform you about the Game.
If you have subscribed for receiving updates and promotions or us and of the local Heineken organization in your country , we and the local Heineken organization will use the email address you have provided to send you these updates and promotions, e.g. through newsletters.
The use of your Personal Data is to process your participation in the Game. It is also used in our legitimate interests to send our customers information about our products, as consented to by you. We or the local Heineken organization will no longer send you updates and promotions once you have opted-out of receiving this information. You can unsubscribe by using the unsubscribe function in each commercial e-mail message.
2.4. Personalized online marketing
We may process and combine information about your interactions with us, your entries, donations, the settings on our Game, and contact details.
Also, we may build a profile of your interests and match this with your other online information. For example, we might use Facebook or Google custom audience or look-a-like services, to the extent permitted by local law. We do this to use different channels for relationship management and marketing, to promote our products and services via e-mail, direct mail, social media, or online advertising. That may include also personalising marketing content and offers and we might use data management platforms to do so.
Where we are legally required to ask you for your prior consent, we will ensure we have obtained such consent. In all other cases, 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, to enable us to attract more customers, to improve the sale of our products. The Personal Data shall generally be deleted or anonymised 2 years after your last entry in our Game, except where we are legally required to retain the Personal Data or where it is kept for any of the other purposes.
You can always opt-out of receiving personalized marketing via e-mail, direct mail. You can always object to our use of your Personal Data for direct marketing purposes by contacting us via email@example.com.
2.5. Participate in research activities
We also may contact you to ask if you would like to participate in 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 it. We will either provide research activities with your consent, or because we have a legitimate interest, depending on the type and nature of the research activity.
3. 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 Game. These third parties are:
- The local Heineken organization in your country of residence to the extent that you have consented to us sharing your personal data;
- The local Heineken organization in your country of residence where this is required for prize fulfilment purposes;
- Service providers where this is needed to provide us with a service and to provide data analytics and data storage services;
- Service providers that help us organize campaigns and promotions, for marketing and research purposes and, if applicable for your country of residence, for prize fulfilment, including Triple IT B.V., M&CSaatchi Sport and Entertainment UK Ltd, SilverBullet Data Services, The Advanced Travel Partner (ATPI) and Beerwulf B.V.;
- Data management platform provider, Relay42, who provides data storage and marketing strategy services;
- Third party providers of Social Media Platforms (including Facebook, and Google);
- Service providers such as solicitors and accountants;
- Courts, parties to litigation and their professional advisers where we reasonably deem it necessary in connection with the establishment, exercise or defence of legal claims; and
- A purchaser or parties interested in purchasing any part of our business.
These parties may be located in the European Union or other countries in the European Economic Area (EEA) or elsewhere in the world. When your 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.
4. Security of Personal Data
5. Retention of Your Personal Data
7. Social Media
You may choose to share information on our Game via social media, such as Facebook, WhatsApp, and Twitter. 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.
8. Children's Privacy
The Game 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.
9. 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 us via this web form (https://www.theheinekencompany.com/data-privacy-request-form). 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. However we will retain Personal Data where it is legally required for us to do so.
You have the right to receive the Personal Data that you have provided to us in a structured, commonly used and machine-readable format. In certain circumstances we will, at your request, transmit your Data to another controller where this is technically feasible.
10. 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 by sending an email to firstname.lastname@example.org.
This version was last updated in May 2021.