BEERWULF Privacy Policy

1. General

This Privacy Policy applies to your use of our website, the BEERWULF webshop and the BEERWULF marketplace (collectively, the “BEERWULF Services”) in the Netherlands, regardless of how you use or access the BEERWULF Services.

Beerwulf B.V. (Stadhouderskade 80, 1073 AT, Amsterdam, the Netherlands) (“we”, “us” or “BEERWULF”) is part of the HEINEKEN group.

Please read this Privacy Policy carefully, as it contains important information to help you understand our practices regarding the personal information you provide to us or that we otherwise collect in connection with the BEERWULF Services (“Personal Data”). BEERWULF is the controller responsible for the collected and processed Personal Data.

We may amend this Privacy Policy at any time by posting the revised Privacy Policy on our website and indicating the effective date of the revised Privacy Policy. You will be notified of any significant changes to this Privacy Policy through your BEERWULF account and/or by email.

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

2. What Personal Data we collect, how we use your Personal Data and how long we retain your Personal Data

We have specified which Personal Data we collect, the purposes for which we use the Personal Data and how long we generally retain your Personal Data.

2.1 Personal Data we process when using our BEERWULF Services or creating a BEERWULF account

Personal Data you provide

• Information identifying you, such as your name, address, telephone number, email addresses and username, which you provide when creating your BEERWULF account or afterwards.
  
• Financial information (e.g. credit card and bank account numbers, transaction details and payment methods).
  
• Shipping, billing and other information you provide (such as shipment numbers and tracking information).
  
• In some cases: age, gender, country of birth, nationality, interests and preferences.
  
• You may provide us with additional information through a web form, by communicating with other users of the BEERWULF marketplace via direct messages or chat, by updating or adding information to your BEERWULF account, through surveys, enquiries, customer service calls recorded with your consent, or when contacting us for any other reason regarding our BEERWULF Services.
  

Personal Data we automatically collect

• Transaction data relating to your purchases or sales, such as transaction amounts, transaction time and location and payment or payout method.
  
• Data generated by your other activities when using our BEERWULF Services and linked to your BEERWULF account, such as placing items in your shopping basket, saving items to your wishlist, saving sellers, searches or interests, viewing pages and products, participating in social media activities (such as through Twitter, LinkedIn, Facebook and Instagram), or through your settings on our website.
  
• Data relating to any other interactions with our BEERWULF Services, your advertising preferences and your communications with us.
  
• Location data, including your approximate location (e.g. IP address).
  
• Computer and connection information, such as statistics about your use of our BEERWULF Services, traffic data to and from websites, referral URLs, advertising data, your IP address, access times, pages visited within our BEERWULF Services, language settings and weblog information.
  

Personal Data we collect through cookies and similar technologies

We use cookies, web beacons and similar technologies to collect data in connection with our BEERWULF Services. We collect this data from the devices (including mobile devices) you use to access our BEERWULF Services.

The collected data includes the following usage and device-related information:

• Information about the pages you visit, access time, frequency and duration of visits, links you click and other actions you take as part of your use of our BEERWULF Services and advertising and email content.
  
• Information about your activities and interactions with sellers and our advertising partners, including data about advertisements shown to you, how often they were displayed, when and where they were displayed and whether you took any action such as clicking on an advertisement or making a purchase.
  
• The user segment or category you belong to, for example: female, 20–49 years old, interested in craft beer.
  
• Model or device type, operating system and version, browser type and settings, device ID or individual device identifier, advertising ID, device token and cookie-related data (e.g. cookie ID).
  
• The IP address from which your device accesses our BEERWULF Services.
  
• Location data via IP address.
  

Please consult our Cookie Policy for more information about our use of these technologies and your choices.

Personal Data we collect from third parties

We also collect Personal Data about you from other sources and third parties to the extent permitted by applicable law. This includes:

• Information from public sources (e.g. demographic data).
  
• Information from credit agencies or bureaux (e.g. credit reports/checks, identity verification, risk modelling data and credit limit determination).
  

We combine or link the Personal Data we collect about you with information from these other sources.

Where Personal Data is disclosed to us by third parties, we take steps to ensure that these third parties are legally permitted to disclose your Personal Data to us.

We also receive access to Personal Data about you from other members of the HEINEKEN group.

2.2 The purposes for which we collect your Personal Data

We require this information:

• to process your order and payment in the BEERWULF webshop and deliver the ordered Products to you;
  
• to facilitate and execute transactions with sellers on the BEERWULF marketplace (including, where necessary, transferring your Personal Data to the seller of the Product you purchase in order to complete the transaction);
  
• to show you your transaction and feedback history;
  
• to provide and improve features such as payment processing, reviews, BEERWULF account management, payment services by our payment service providers and ensuring and improving the functionality of our marketplace;
  
• to contact you for customer service purposes, such as product recalls or other service-related communications. For these purposes, we require your email address, name and/or telephone number. We register your requests, questions and our responses and other actions required to handle your request. We record calls when you contact us by telephone. You are free to indicate at the start of the call that you do not wish the call to be recorded;
  
• to send you commercial communications regarding our Products and BEERWULF Services and similar Products you have ordered, where you have given consent and subscribed to our newsletter. Where legally required, we will ask for prior consent before sending commercial communications. In the case of an existing business relationship, we use your Personal Data because it is in our legitimate interest to provide information about our Products to existing customers. We will remove your email address once you unsubscribe from newsletters, unless it is retained for other purposes specified in this Privacy Policy. You may unsubscribe at any time using the unsubscribe function in every email or by contacting us;
  
• to enable us to use different channels for relationship management and marketing our Products and Services to you via email, post, social media, apps or online advertising, including personalising media content and offers according to your preferences;
  
• to personalise content and offers and create segments. Information about your use of our website and BEERWULF Services enables us to create segments, meaning groups of website visitors or customers with common characteristics such as age group, gender or region. Segments are used to adapt the website and, for example, alter the order of search results or position offers more likely to interest you. We may also use segments to display online advertisements or send emails we believe are relevant to you;
  
• to use your Personal Data for website maintenance and analysis, troubleshooting performance issues, improving availability and protecting our website against fraud (for example in cases of repeated login attempts or purchases made in breach of our terms, such as purchases by persons under 18 years old). Analysis also allows us to check whether the online ordering process works efficiently so we can improve it where possible;
  
• to ask you to participate in research activities such as surveys, pilots, panels, focus groups, Net Promoter Score (NPS) surveys and other research activities. Depending on the research activity, we may collect and share different sets of (pseudonymised) Personal Data. You will always be informed in advance about which Personal Data we collect, the purposes for collection and with whom the Personal Data will be shared;
  
• to administer sweepstakes, competitions or other promotions you choose to participate in. Some promotions have additional rules explaining how we use and disclose your Personal Data, so please review the applicable Privacy Policy where relevant.

2.3 Legal basis for processing your Personal Data

We process your Personal Data:

• to perform our contract with you and provide you with our BEERWULF Services.
  

For example: the provision of our BEERWULF Services, including but not limited to facilitating and carrying out transactions with sellers on the BEERWULF marketplace (including sharing your Personal Data with sellers where necessary to complete the transaction, including in cases of terminated, failed or subsequently cancelled transactions, for example by sharing your return address so that you can return an item), and enabling the delivery of purchased items from the BEERWULF webshop by logistics/shipping providers;

• to comply with legal obligations to which we are subject.
  

For example: participation in investigations and proceedings (including legal proceedings) conducted by governmental authorities or public bodies for the detection, investigation and prosecution of illegal acts and the prevention, detection and mitigation of unlawful activities (such as fraud, money laundering and terrorist financing);

• for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms.
  

For example: monitoring and improving the information security of our Services, unless required by law, or (where permitted under applicable law) communicating with you by electronic communication (such as email or SMS) or telephone to offer vouchers, discounts and special offers, conduct opinion polls and surveys, and inform you about our BEERWULF Services without requiring your consent;

• with your consent.
  

For example: personalising, measuring and improving advertisements in our online offering, the online offering of BEERWULF or companies within the HEINEKEN group, and marketing communications by telephone or electronic communication (such as email or SMS), including communications from other companies within the HEINEKEN group or from third parties, unless such communications are permitted without your consent under applicable law.

2.4 How long we retain your Personal Data

• General account and transaction data:
  
  We retain your BEERWULF account information for as long as you actively use your BEERWULF account. After a period of 1 year of inactivity, we delete your BEERWULF account. You may also request deletion of your BEERWULF account via Contact Us.
  

Your Personal Data relating to your BEERWULF account and transactions will be deleted or anonymised 2 years after your last purchase through the BEERWULF webshop or marketplace, except where we are legally required to retain the Personal Data or where it is retained for one of the other purposes specified.

• Customer service data:
  
  BEERWULF retains all information for 1 year after your enquiry or complaint has been resolved or the investigation has been completed, except where we are legally required to retain the Personal Data or where it is retained for one of the other purposes specified.
  
• Financial information:
  
  This data is retained in order to comply with legal obligations, such as tax and accounting regulations. Our online sales records are retained for 7 years, or longer where required by tax authorities or corporate accounting requirements.
  

You may manage your information within your BEERWULF account (for example, your previous purchases) and review it at any time.

In our commercial emails, we refer to a preference centre. In this preference centre, we ask questions about your use of our Products. These questions may relate to usage occasions, preferred brands, preferred Products or specific information you may or may not wish to receive.

You may proactively complete this information yourself so that we gain a better understanding of how you use our Products. We may use this information to send you specific offers, discounts or other commercial communications tailored to your preferences or to exclude you from certain communications.

You are not obliged to provide this information.

3. How we share your Personal Data

As part of a global business, we share Personal Data (e.g. name, email address, telephone number) and information obtained through cookies (“Cookie Data”) with companies within the HEINEKEN group for aggregated analytical and operational purposes and for (re)targeting, developing behavioural prediction models, creating consumer or lookalike audiences (where permitted by local law), and enriching existing customer profiles.

We will only share such Personal Data and Cookie Data where permitted by applicable (local) law. This means we will request prior consent where this is the legal basis we rely on. Where we are permitted to rely on legitimate interest, we will do so. This applies, for example, where we create insights using aggregated customer data to improve our marketing efforts.

We are required to share Personal Data with third parties to help us provide the BEERWULF Services to you. These third parties include:

• Service providers, where necessary to provide a service to us or assist us in providing the service or Product ordered through the BEERWULF webshop or marketplace (including our external delivery providers) and to provide data analytics services. We work with the following service providers: DHL, DPD, Yodel, Asendia, PostNL, UPS, Bartolini, HubEurope, Europa Logistics, Kuehne+Nagel, SendCloud, Centiro, Klaviyo, 5CA, Zendesk, Obi4Wan, Staffords, Zowie, Mopinion, Channable, Funnel.io, Gocertify.me, Impact, Veritonic and Crunch Analytics.
  
• Stripe Inc., a payment service provider acting as controller for receiving and processing payments made through the BEERWULF webshop and marketplace. More information about how Stripe Inc. uses your Personal Data can be found here.
  
• Sellers, meaning the companies selling their Products on the BEERWULF marketplace.
  
• Additionally, we may use, disclose or transfer your information to a HEINEKEN group company in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or part of our business, assets or shares (including in connection with bankruptcy or similar proceedings).
  
• Independent debt collection agencies, lawyers or other agents for the collection of outstanding amounts on your account.
  
• In the event that HEINEKEN sells all or part of the assets or shares of a HEINEKEN group company to which Personal Data has been transferred, your Personal Data may be provided to that third party.
  
• First and third-party advertising companies.
  
• Media agencies for marketing and research purposes.
  
• Social media providers such as Twitter, LinkedIn, Facebook and Instagram.
  

Additionally, we may need to disclose your Personal Data to the following third parties in order to comply with legal obligations:

• Law enforcement authorities, courts, governmental authorities or public bodies, intergovernmental or supranational organisations.
  
• Third parties based on lawful information requests addressed to us.
  
• Third parties involved in legal proceedings where they provide us with a court order or equivalent legal order.
  

We may transfer your Personal Data to recipients located anywhere in the world.

We will only transfer your Personal Data from the European Economic Area (EEA), the United Kingdom or Switzerland to third countries, meaning countries outside the EEA, on the basis of appropriate safeguards or where otherwise permitted under applicable law.

Third countries currently recognised by the European Commission as providing an adequate level of data protection include Andorra, Argentina, Canada (for organisations subject to the Personal Information Protection and Electronic Documents Act), Switzerland (for transfers outside the EEA), the Faroe Islands, Guernsey, the State of Israel, the Isle of Man, Japan, Jersey, New Zealand, the United Kingdom and Uruguay.

In other cases, BEERWULF ensures appropriate safeguards are in place, for example by entering into standard contractual clauses approved by the European Commission with recipients or by implementing other measures provided for under applicable law.