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Privacy Policy

  1. General


This Privacy Policy applies to our website dedicated to our brand [Bralirwa in [Rwanda], available at [https://bralirwa.co.rw] (the "Website") where we, [BRASSERIES ET LIMONADERIES DU RWANDA (BRALIRWA) Plc, (Kicukiro, B.P. 131 Kigali) collect certain personal data. [BRASSERIES ET LIMONADERIES DU RWANDA (BRALIRWA) Plc] (‘we’ or ‘us’) is the controller of the Personal Data collected and processed. We are part of the HEINEKEN Group. However, where processing is undertaken for the purpose of globally strategic reporting & insights and marketing activations, HEINEKEN International B.V. is considered to be a separate data controller of your Personal Data.


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”).


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

You can use the majority of our Website without being required to provide any Personal Data to us. For certain services or activities you will need to provide Personal Data for us to be able to provide you the requested service or product or for you to participate in the activity. 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 or you cannot participate in the activity. In addition to information you are required to provide to us in order to participate in activities/campaigns, we collect certain information when you visit our Website.


  • participation in campaigns, prize draws, contests

If you take part in contests or events (including prize with purchase promotions (including giveaways, instant wins and online, mobile, social media and app entries), loyalty and reward schemes, activity challenge, sweepstake, scratch-card and raffle style promotions (including instant wins and online, mobile, social media and app entries); sampling and point of sales promotions and geo-targeted activities (including gamification and SMS), depending on the campaign, prize draw or contest you will be asked for your name, email address, home address, telephone number and answers to open questions in order to ‘win’. If needed to send you the prizes per regular mail (e.g. as for tickets or products), we will also ask for your physical address or we may ask other specific details needed to award your prize to you. We need this information to process your participation and to be able to communicate with you about your prize or to send the prizes to you. All information about your participation in our campaigns, prize draws and contests will be retained by us for a maximum period of 6 months after the end of the contest. The information will not be used for other purposes if you have not explicitly been informed about these purposes and/or have been asked for prior consent.


  • information when you contact us

If you visit our Website and have a question or other remark, you can submit our Contact Form. You will be asked to provide your name and email address and obviously information about your request. We will only use this information to respond to your question. We will register your requests, questions and our responses and other actions to handle your request. We will retain all information for 6 months after your question or complaint has been solved or the inquiry was closed.


  • information about your visit to and use of our Website

We collect certain information when you visit our Website, such as your IP address, which web pages you visit, device category, browser, and type of internet browser, clicks and views. 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 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 and to send you commercial messages.


We use this Personal Data as it is necessary in our legitimate interests to do so to promote our products and services to our consumers and website visitors, to enable us to attract more website visitors, to improve the sale of our products and services. We will retain the Personal Data for a maximum of 14 months.


  • 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 XX year period of inactivity, we will delete your account. You can also request to remove your account via [eric.manzi@heineken.com, and/or phone: +25781469990]. 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 your 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 [Email: eric.manzi@heineken.com, and/or phone: +250781469990]


  • 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. We also use the information that you have provided for the purposes of verifying your identity and carrying out anti-money laundering and credit checks against you (this may include use of a credit reference agency or other third parties).


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. It is also necessary for our legitimate interests to ensure we are doing business with creditworthy and legitimate entities, which requires an analysis of certain individuals within. Our online sales records will be retained by us for [3 years from the end of the business relationship] or [XX] years or longer if required by tax or corporate bookkeeping.  To deliver our products and services to you:



  • sending commercial messages:

We send you commercial messages in multiple ways. You can subscribe to receiving commercial messages (e.g. newsletter), in that case we will use the contact details (such as your email address, social media account or phone number) you have provided to send you our commercial messages. Furthermore, when you purchase a product from us, you will also automatically be added to our customer database and therefore you will receive commercial messages about similar products or services, unless you object to this processing of personal data at the time of your purchase. If you no longer wish to receive any commercial messages from us, you can unsubscribe at any time by using the unsubscribe function in each e-mail message (or read the paragraphs below for more information about how to do this).


In the case of an existing business relationship, it is in our legitimate interests to use Personal Data to send our existing customers information about our products. When we are legally required, we ask for prior consent to send you commercial messages. We will remove your contact details once you have opted-out of receiving commercial messages, unless this is also used and retained for other purposes listed in this Privacy Policy.


  • personalized marketing

Information about your online searches and social media activity (such as Twitter, LinkedIn, Google, Facebook & Instagram) (clicks and views), your settings on our Website, your customer service requests and contact history can be combined by us. This information enables us to build a profile of your interests and to match this with your other online information (for example by using Facebook or Google Custom audience services or look-a-like services to the extent allowed under applicable law) in order for us to use different channels for relationship management and marketing of our products and services to you via e-mail, direct mail, social media, telephone or online advertising which may include personalising website marketing content and offers, in particular when we use data management platforms, so these are tailored to your preferences.


You can always opt-out of receiving our newsletter and object to our use of your Personal Data for direct marketing purposes.


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 maintain the relevance of our brands and reputation and to grow business by serving consumers with advertising relating to our brands and to finance our Website (via online advertisements). We will ask for prior consent, when we are legally required (for example when we use data for ‘direct marketing’).


We will retain the Personal Data as specified under the relevant purposes for which the Personal Data has been collected (e.g. newsletters, account information, processing orders and payments). The Personal Data shall generally be deleted or anonymised 24 months years after your last relevant activity 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.


  • maintenance and optimisation of our Website

Your Personal Data will also be used for maintenance and analysis of our Website to solve performance issues, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, to improve the availability and user experience of the Website and to secure the Website against fraud. We log all use of our Website.


Our use of your Personal Data for these purposes is necessary in our legitimate interests and the information will be retained for a maximum period of 14 months. The logs of the use of our Website will be deleted within 14 months after creation.


  • participate in research activities

We may request you 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 this Personal data.


Our use of your Personal Data for research activities is necessary in our legitimate interest to ensure we offer a good quality service and products and to further improve or based on your prior specific consent, depending on the type of research activity and which Personal Data we will collect from you. The Personal Data will be retained for a maximum period of 24 months.


  • using photo and /or video footage

The Personal Data may include photo and/ or video footage captured at public or private events on social media, with marketing agencies and internally. We may share these photos and video footage on our Website or use social media to promote our products and brands and grow our business. Where required by law, we will first obtain your consent to use this data. We will retain the data for 6 years from the time the photo or video recording was captured.


  • strategic reporting purposes, creating insights

The Personal Data collected by us is accessed and used by Heineken International B.V. to create aggregated strategic reports with insights which are used to identify opportunities globally and to improve our global brands, products and services.


Heineken International B.V. uses this information as it is in the legitimate interest of the HEINEKEN Group and all affiliates and subsidiaries to identify opportunities globally and to promote and improve our products and services to our customers and website visitors and to maintain the relevance of our brands and reputation. Your information will be retained for a maximum period of 6 years. We will ask for prior consent, when we are legally required (for example when we use data for ‘direct marketing’).


  1. How We Share Your Personal Data


As member of a global business, we share Personal Data and information we have acquired via ‘cookies’ with Heineken International B.V. for reasons as strategic reporting and for creating insights and marketing activation as further described under 2. In this Policy. We will only share such Personal Data and cookie data when we are allowed to do so by law. This means that we will ask for prior consent, if this should be the lawful basis (for example when we share cookie data). When we are allowed to rely on our legitimate interest, we will do so. This is the case when we create aggregated marketing insights or segments. 


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 and to provide data analytics services
  • service providers that help us organize campaigns and promotions
  • first and third party advertising companies
  • media agencies for marketing purposes and research purposes
  • social media service providers
  • customers (those who resell or buy or record data from sales of Opco’s products
  • HEINEKEN group companies 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)
  • Legal Services providers
  • 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 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.


  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 table. Techniques we use that may be similar to cookies are tracking pixels, Java scripts, tags and web beacons. 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, which is also available in the footer of this Website.

  1. Social Media

You may choose to share information on our Website via social media, such as [Facebook, Instagram, LinkedIn, Twitter and YouTube]. 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


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

If 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 request restricted processing or to stop processing or using your personal data for profiling, 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, our Website services anymore. 


  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 rights listed above, if you have any other question or a complaint about this Privacy Policy or about our handling of your Personal Data, please contact us [david.karuhanga@heineken.com, and/or phone: +250788227100].