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Beerwulf Privacy Policy

General

This Privacy Policy concerns the collection of certain Personal Data from consumers in Italy through the BEERWULF website, available at https://www.beerwulf.com/it-it (the “Website”), operated by Beerwulf B.V. (Stadhouderskade 80, 1073 AT Amsterdam, the Netherlands) (“Beerwulf”). Beerwulf is part of the HEINEKEN Group (HEINEKEN N.V.).

Please read this Privacy Policy carefully, as it contains important information to help you understand Beerwulf’s practices regarding the Personal Data you provide or that is otherwise collected in connection with the Website (“Personal Data”). Beerwulf B.V. (“we” or “Beerwulf”) is the controller of the Personal Data collected and processed.

We respect your privacy and are committed to keeping your Personal Data secure and managing it in accordance with our legal obligations under applicable data protection laws.

What Personal Data we collect about you and how we use it

You can use most of the Website without having to provide any Personal Data. For some Website services and purposes, it is necessary for you to provide us with Personal Data, for example so that we can fulfil your orders or send you our newsletters or other information.

In addition to the information you are asked to provide, we collect certain information when you visit the Website. Some information requested on the Website is mandatory. If you do not provide the requested data, we will not be able to provide you with the desired product or service.

Below we specify the Personal Data we collect, the purposes for which we use it and how long we generally retain your Personal Data.

1) Fulfilling your order, processing payment and delivering the requested product or service

We need your name, email address, telephone number, your physical address or the address of the recipient of our services, date of birth and payment information. This information is also necessary for sales management purposes.

The legal basis for using this Personal Data is the performance of our agreement with you or compliance with legal obligations, such as tax and accounting rules. Our online sales records will be retained for 7 years or longer if required by tax or accounting provisions.

2) Registration and account creation on the Website

Before making a purchase, you may create an account and provide us with a username and password, as well as an email address, first name/surname, telephone number, billing address and date of birth. We use this information to fulfil your order or contact you in case of irregularities relating to the order.

You can manage your account information yourself and view, for example, previous purchases. Account data is retained for as long as you actively use the account. After 1 year of inactivity, we will delete the account. You may also request deletion of your account as indicated in the Contact section.

You may also choose to purchase our products as a “guest”. As a guest, we will save your orders in our back-end database and create a unique customer ID containing your contact details. If you make another purchase, we can link the new order to those contact details. We do this to avoid duplicate data and ensure fulfilment of your purchase order. You may also request deletion of this data as indicated in the Contact section.

3) Customer services

You can ask us questions via the Website or by phone. Beerwulf may also contact you in the event of product recalls or to send you other service emails.

For this purpose, we process your email address, name and/or telephone number. We record your requests and questions, as well as our responses and actions taken to handle them. We will record calls when you contact us by phone. You may object to such recording at the beginning of the call.

BEERWULF will retain all your information for 1 year after the question or complaint has been resolved or the request for information has been completed.

4) Marketing

If you have subscribed to our newsletter, we use the email address you provided for that purpose (“opt-in”). If you have placed orders with us, we may also send you newsletters to inform you about other similar products we offer that we believe may be of interest to you (“soft opt-in”). If you no longer wish to receive marketing messages from us, you can unsubscribe at any time using the opt-out feature included in every email message or by contacting us.

We use this Personal Data to promote our products and services, to improve sales, and to maintain or enhance our business relationship with you. Before sending you commercial messages, we will request your consent, unless soft opt-in applies. We will retain Personal Data as specified for the relevant purposes for which it was collected (e.g., newsletters, marketing). Personal Data will generally be deleted or anonymized two years after your last order on our Website.

5) Profiling and personalization

We may combine information related to purchases, online searches, and social media activity, clicks and views, settings on our Website, items in your shopping cart, customer service requests, and your contact history. This information allows us to use various channels for relationship management and direct marketing of our products to you, via personalized emails, postal mail, social media interactions, apps, or online ads, based on your preferences.

We use this Personal Data because it is necessary, in our legitimate interest, to promote our products and services to our customers and Website visitors, to help us attract more customers, and to improve sales of our products. We will request prior consent when required by law.

Personal Data will be retained for (direct) marketing purposes in accordance with applicable laws and regulations starting from the date of the customer’s last order.

6) Information about your visit to and use of our Website

When you visit our Website, we use cookies and similar technologies to collect certain information, such as your IP address, which pages on the Website you have visited, the type of web browser you are using, your clicks and page views, and the type of device and operating system you are using. In addition, we track whether you have opened our newsletter and clicked on any links contained therein. This information allows us to create segments—that is, groups of Website visitors or customers with various common characteristics, such as age group, interest category, or region. We may add you to one of our segments, which we may also use to show you online ads or send you emails that we believe are of interest to you.

Before using analytical or tracking cookies, we will request the user’s prior consent. For more information, please also refer to section 6 below and our Cookie Policy.

7) Website maintenance and optimisation

Your Personal Data will also be used for maintenance and analysis of our Website, to resolve performance issues, improve availability and protect the Website against fraud, for example in the event of repeated login or purchase attempts, or if a purchase is made in breach of our terms and conditions, such as by individuals under 18.

The analysis also allows us to check whether the online ordering process works efficiently and improve it where possible.

Because using your Personal Data for these purposes is necessary to pursue our legitimate interests, such data will be retained. For more information on how long Personal Data collected through cookies is retained, please consult our Cookie Policy.

8) Participation in research activities

We may also ask you to participate in research activities such as surveys, pilot projects, focus groups and other research activities.

Depending on the research activity, we will collect different types of Personal Data. You will always be informed before the start of the research activity about which Personal Data we will collect and for what purpose.

Research activities will be based on your consent or our legitimate interests, depending on the type and nature of the research activity.

9) Participation in prize draws, competitions or other promotions

We use your Personal Data to manage prize draws, competitions or other promotions in which you choose to participate. Some of these promotions have additional rules containing information on how we will use and disclose your Personal Data.

We use this information to manage our contractual relationship with you.

3. How we share your Personal Data

As a subsidiary of a global company, we share Personal Data (such as name, email address, and phone number) and information we have collected through cookies or similar technologies (“ Cookie Data”) with affiliates and subsidiaries of the HEINEKEN Group for aggregate analytical and operational purposes, for (re)targeting, for developing behavioral prediction models, for creating consumer audiences or similar audiences (to the extent permitted by local law), and for enriching existing customer profiles. We will share such Personal Data and Cookie Data only when (local) law permits us to do so. This means that we will request your prior consent when relying on this legal basis, while we will rely on our legitimate interest where permitted, for example to derive analytical insights from aggregated customer data to improve our marketing activities.

We must share Personal Data with certain third parties. These third parties are service providers necessary to provide us with a service or to (be able to) provide or deliver the service or product you ordered on the Website (including our third-party delivery service provider) and to provide data analytics services. The service providers we work with include:

our logistics and customer service partners, such as third-party logistics providers who handle the fulfillment and delivery of our products and the ticketing systems for user requests;

payment service providers who will act as “data controllers” to receive and process payments made by you through the Website. Details on how these providers use your Personal Data are set forth in their respective privacy policies;

In addition, we may use, disclose, or transfer your information to a HEINEKEN group company in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or part of our business, assets, or shares (including in connection with any bankruptcy or similar proceedings);

independent debt collection agencies, attorneys, or other parties engaged for the purpose of collecting amounts owed or outstanding on your account;

in the event that HEINEKEN sells to a third party all or some of the assets or shares of a HEINEKEN group company to which Personal Data has been transferred, your Personal Data may be provided to such third party;

first- and third-party advertising companies;

communications agencies for marketing and research purposes;

social media providers, such as Facebook, Instagram, or X.

These third parties may be located in the Netherlands, the United Kingdom, France, Germany, Belgium, other countries within the European Economic Area (“EEA”), or elsewhere in the world. When we transfer Personal Data outside the EEA, we will ensure an adequate level of protection for the transferred data by ensuring that appropriate legal safeguards are in place.

We require service providers to implement appropriate technical and organizational measures to protect the confidentiality and security of Personal Data.

We may also be required to provide Personal Data to law enforcement authorities to comply with a legal obligation or a court order.

4. Security of Personal Data

We will take appropriate technical, physical, and organizational measures to protect your Personal Data from misuse or accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, acquisition, or access, in accordance with applicable laws and regulations regarding privacy and data security.

However, no website or Internet-based service can be 100% secure, and we cannot be held liable for unauthorized or inadvertent access beyond our control.

Our Website may contain links to other websites. We are not responsible for the privacy practices, content, or security of such other websites, which are not governed by this Privacy Policy. We recommend that you always read the privacy policies of these other websites carefully.

5. Retention of your Personal Data

We will retain your Personal Data for as long as required by law, for as long as necessary to provide you with the requested services, or for any of the other purposes listed in this Privacy Policy. The specific retention periods are set forth in this Privacy Policy for each of the relevant purposes. We will take reasonable steps to destroy or anonymize the Personal Data in our possession if it is no longer necessary for the purposes described above or after the defined retention period has expired.

6. Cookies

Some of the information mentioned in this Privacy Policy is collected through the use of cookies and similar technologies. Cookies are small text files containing small amounts of information that are downloaded and may be stored on the user’s device, such as a computer, smartphone, or tablet. The similar technologies we use are so-called pixels, which can be used to track your interactions with the Website. These cookies and similar technologies are sometimes necessary to remember your account settings, language, and country, but they also allow us to measure and analyze your behavior on our Website and to show you personalized advertisements on our Website or on third-party websites. Where required, we will ask you to consent to our use of cookies. For more information about the cookies we use and how we use them, please see our specific https://beerwulf.com/pages/cookie-policy.

7. Social media

You may choose to share information from our Website via social media platforms such as Facebook, Instagram, and X. This means that the information you share, including your name and preferences, will be visible to visitors to your personal pages. We recommend that you carefully read the privacy policies of these social media platforms, which govern their processing of your Personal Data.

8. Children’s privacy

This Website 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. User Rights Regarding Access, Rectification, Erasure, Restriction, and Data Portability

You have the right to request an overview of your Personal Data processed by us or on our behalf. You have the right to request the rectification, erasure, or restriction of the processing of your Personal Data (where applicable). You may exercise this right by contacting service@beerwulf.com. Please note that requests that do not meet the requirements established by applicable law or BEERWULF’s guidelines may need to be resubmitted or, as a last resort, may be denied, and that certain Personal Data may be exempt from such requests for access, rectification, and erasure, in accordance with applicable data protection laws or other laws and regulations.

You have the right to receive the Personal Data you have provided to us in a structured, commonly used, and machine-readable format, and, under certain circumstances, upon your request, we will transmit your Personal Data to another data controller, where technically feasible.

10. Right to Object

You also have the right, under certain circumstances, to request that we stop processing your Personal Data, unless we have compelling legitimate grounds to continue processing it, in which case we may continue to do so. However, you have the right to object to our use of your Personal Data for direct marketing purposes, including profiling, and, in such cases, we will comply with your request. Where you have provided consent for our use of your Personal Data, you have the right to withdraw it without affecting the lawfulness of our use of such Personal Data prior to withdrawal.

11. Updates

We will continue to review this Privacy Policy and update it periodically. Any changes to this Privacy Policy will be posted on our Website and, to the extent reasonably possible, will be communicated to you.

12. Contact Us

If you have any questions, objections to our use of your Personal Data, or complaints regarding this Privacy Policy or our handling of your Personal Data, you may contact us at service@beerwulf.com. You also have the right to file a complaint with your local data protection authority.

Last updated: June 2025

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