Privacy Policy

1. General

This Privacy Policy applies to our BEERWULF website for consumers in Austria, available at https://www.beerwulf.com (the “Website”), on which we, Beerwulf B.V. (Westeinde 16, 1017 ZP Amsterdam, the Netherlands) (“Beerwulf”), collect certain Personal Data. Beerwulf belongs to the HEINEKEN Group.

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

We respect your privacy and are committed to protecting your Personal Data and managing it in accordance with our legal responsibilities and applicable data protection laws.

What Personal Data we collect and how we use your Personal Data

You can use most of our Website without having to provide us with Personal Data. For certain services and purposes of the Website, you must provide us with Personal Data, for example so that we can process your orders or send newsletters or other information to you.

In addition to the information you are required to provide, we collect certain data when you visit our Website. Some information requested on the Website is mandatory. If you do not provide the requested information, we cannot provide the service or deliver the Product to you.

We have set out the Personal Data we collect, the purposes for which we use it and how long we generally retain your Personal Data:

1) Processing your order

To process your payment and deliver the requested Product or service to you, we need your name, email address, telephone number, postal address or the address of the recipient of our services, date of birth and payment information. This also applies to our sales administration.

We use this Personal Data to perform our agreement with you or to comply with legal obligations, such as tax and accounting rules. Our online sales records are retained for 7 years or longer if required for tax or corporate accounting purposes.

Registration and creating an account on our Website

Before making a purchase, you can create an account and provide us with a login name and password, which we need to manage your account, as well as an email address, first name/surname, telephone number, billing address and date of birth, which we use to process your order or contact you in case of irregularities relating to your order.

You can manage the information in your account yourself and, for example, see which purchases you have made so far. We store your account data for as long as you actively use your account. After 1 year of inactivity, we will delete your account. You can also request deletion of your account via the Contact button.

You also have the option to purchase our Products as a “guest”. As a guest, we store your order in the backend and create a unique customer ID containing your contact details. If you then make another purchase, we can link that order to the same contact details. We do this to avoid duplicate data and to ensure that we can fulfil your order. You can also request deletion of this data via the Contact button.

2) Customer service

If you have any questions, you can contact us at any time via the Website or by telephone. We may also contact you regarding Product recalls or other service emails.

For this purpose, we process your email address, name and/or telephone number. We store your requests, questions and our responses, as well as other actions we take to handle your request. We record calls when you contact us by telephone. You can state at the beginning of the call that you do not want the call to be recorded.

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

3) Sending promotional messages

We use various channels to send you promotional messages. You can subscribe to receive promotional messages, such as newsletters. In that case, we use the contact details you provided, such as your email address, social media account or telephone number, to send you our promotional messages.

In addition, when you purchase a Product from us, you are automatically added to our customer database and will therefore receive promotional messages about similar Products or services, unless you object to this processing of Personal Data at the time of purchase.

If you no longer wish to receive promotional messages from us, you can unsubscribe at any time using the unsubscribe function in each email message, or you can inform us via Contact.

Where we are legally required to do so, we will ask for your prior consent to send you promotional messages. In the case of an existing business relationship, we use your Personal Data because it is in our legitimate interest to send our existing customers information about our Products.

We will delete your contact details once you unsubscribe from receiving promotional messages, unless those contact details are also used and retained for other purposes listed in this Privacy Policy.

4) Marketing

Information about your purchases, online searches and social media activities, such as Twitter, LinkedIn, Facebook and Instagram, including clicks and views, your settings on our Website, the items in your basket, your customer service requests and your contact history may be combined by us.

This information enables us to use various channels for customer relationship management and marketing our Products and services to you through promotional messages, emails, social media, apps or online advertising. This may include personalising Website, email, app and social media content and offers so they are tailored to your preferences.

You may unsubscribe from receiving our newsletter or direct advertising at any time and object to our use of your Personal Data for direct marketing purposes. For more information, see sections 8 and 9 below regarding your rights.

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

You can proactively complete this information to help us better understand how you may use our Products. We may use this information to send you specific offers, discounts or other promotional messages that match the preferences you entered, or to exclude you from certain messages. You are not obliged to enter this information.

We use this Personal Data where necessary for our legitimate interests, to promote our Products and services to our customers and Website visitors, attract more customers, improve sales of our Products and services and fund our Website through online advertising. We will obtain your prior consent where legally required.

We will store the Personal Data as stated under the respective purposes for which it was collected, such as newsletters, account data, order processing and payment processing. Personal Data is generally deleted or anonymised 2 years after your last order on our Website, unless we are legally required to store the Personal Data or retain it for one of the other purposes.

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

We collect certain information when you visit our Website, such as the web pages you visit, clicks and views, the type of device you use, the operating system you use and the type of internet browser.

We also track how you use our newsletter, which pages you view and which parts you read, so that we can tailor the newsletter to your preferences.

Information about your use of our Website and services enables us to create segments, meaning groups of Website visitors or customers with 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 adapt the Website and, for example, change the order of search results or place certain offers so that you are more likely to see them. We may also use segments to display online advertising or send emails that are relevant to you.

We use this Personal Data where necessary for our legitimate interests, to promote our Products and services to customers and Website visitors, attract more customers, improve sales of our Products and services and fund our Website through online advertising. Please read our Cookie Policy to find out how long Personal Data collected through cookies is retained.

6) Maintenance and optimisation of our Website

Your Personal Data is also used for maintenance and analysis of our Website, to resolve performance issues, improve availability and protect the Website against fraud, for example in cases of repeated attempts to log in or make a purchase, or where a purchase is made in breach of our terms and conditions, such as by persons under 18.

The analysis also allows us to check whether the online ordering process works efficiently so that we can make improvements wherever possible.

Our use of your Personal Data for these purposes is necessary for our legitimate interests. Please read our Cookie Policy to find out how long Personal Data collected through cookies is retained.

7) Participation in analysis activities

We may also ask you to participate in analysis activities, such as surveys, pilots, panels, focus groups and other analysis activities.

Depending on the analysis activity, we will collect different sets of Personal Data. You will always be informed before the analysis activity which Personal Data we collect and for what purpose.

We carry out analysis activities either with your consent or because we have a legitimate interest in doing so, depending on the type and nature of the analysis activity.

8) Allowing you to participate in prize draws, competitions or other promotions

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

We use this information to perform and manage our contractual relationship with you after you have entered the prize draw, competition or other promotion.

9) Enabling Trusted Shops services

Beerwulf holds the “Trusted Shops” certificate and has integrated the Trusted Shops badge (“Trustbadge”) on its Website. This is a graphical representation from Trusted Shops that is visible on the homepage of our Website.

When you click on the Trustbadge, a cookie is set and the following data is transmitted to Trusted Shops GmbH, Subbelrather Str. 15C, 50823 Cologne, Germany: server log file with your IP address, date and time of clicking on the Trustbadge on our Website.

This data is deleted by Trusted Shops after 7 days. Beerwulf has no access to this data.

We also use Trusted Shops to send you an email asking you to rate and review your order. These emails are only sent to people who have consented to receive messages from Beerwulf.

The following data is shared with Trusted Shops and may only be used for this purpose: email address, name and Product URL, Product image, Product name, Product SKU, GTIN and MPN, manufacturer.

Your information submitted as part of the rating and review, which may include your name, may be used by Beerwulf for promotional purposes.

Finally, during checkout you may choose to use the Trusted Shops buyer protection service. Your purchase date, purchase number, customer ID, amount, currency, delivery date, payment method and email address will then be shared with Trusted Shops for this purpose.

Further information about this service can be found in the Trusted Shops policy.

How we share your Personal Data

As part of a global company, we share information obtained through cookies with affiliates and subsidiaries of the HEINEKEN Group for purposes such as aggregated analytical and operational purposes and for retargeting, creating consumer audiences or lookalike audiences where permitted by local law, and enriching existing customer profiles.

We only share such Cookie Data where legally permitted. This means that we will ask for prior consent where this is the legal basis. Where we are permitted to rely on our legitimate interest, we will do so. This is the case when we create aggregated marketing insights or segments.

We need to share Personal Data with third parties so that we can provide you with services and Products and operate our Website. These third parties are:

• service providers, where necessary to provide a service to us or to help us provide the service or Product you ordered on the Website, including our external delivery provider, and to provide data analytics services. Service providers we work with include: 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;
  
• Adyen B.V., a payment service provider acting as controller to receive and process payments made by you via the Website. Please read more here about how Adyen uses your Personal Data;
  
• in addition, in the event of any restructuring, merger, sale, joint venture, assignment, transfer or other disposal of all or part of our business, assets or shares, including in connection with possible bankruptcy or similar proceedings, we may use, disclose or transfer your data to a company within the HEINEKEN Group;
  
• independent debt collection agencies, lawyers or other representatives for the purpose of collecting amounts due or outstanding on your account;
  
• if HEINEKEN sells all or some assets or shares of a HEINEKEN Group company to which Personal Data has been transferred, your Personal Data may be disclosed to that third party;
  
• first-party and third-party advertising companies;
  
• media agencies for marketing and analysis purposes;
  
• social media providers such as Twitter, LinkedIn, Facebook and Instagram.
  

These third parties may be based in the Netherlands, the United Kingdom, France, Germany, Belgium or other countries in the European Economic Area, or elsewhere in the world.

Where Personal Data is transferred by us outside the EEA, we ensure that the transferred data is adequately protected. We require service providers to take appropriate measures to ensure the confidentiality and protection of Personal Data.

We may also need to disclose Personal Data to law enforcement authorities to comply with legal obligations or court orders.

Security of Personal Data

We will take appropriate technical, physical and organisational measures to protect the Personal Data collected through the Website against misuse or accidental, unlawful or unauthorised destruction, loss, alteration, disclosure, acquisition or access.

These measures comply with applicable data protection laws and regulations. However, no internet-based Website can be 100% secure and we cannot be held responsible for unauthorised or unintended access beyond our control.

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

Retention of your Personal Data

We will store your Personal Data for as long as legally required or 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 out in this Privacy Policy for each relevant purpose. We will take reasonable steps to destroy or anonymise Personal Data we hold when it is no longer needed for the purposes above or after expiry of the defined retention period.

Cookies

Much of the information referred to in this Privacy Policy is collected through our use of cookies and similar technologies.

Cookies are small text files containing small amounts of information that can be downloaded and stored on your device, such as your computer, smartphone or tablet. Technologies we use that are similar to cookies include tracking pixels.

These cookies and similar technologies are sometimes necessary to remember your account settings, language and country, but also allow us to measure and analyse your behaviour on our Website and show you personalised advertising on our Website or on third-party websites.

Where required, you will be asked for consent to our use of cookies. For more information about which cookies we use and how we use them, please consult our separate Cookie Policy.

Social media

You have the option to share information on our Website via social media, such as Facebook, Instagram and Twitter.

This means that the information you share, including name and preferences, may be visible to visitors of your personal pages.

We recommend that you carefully read the privacy policies of the social media providers, as these apply to the processing of your Personal Data by those parties.

Protection of minors

The Website is not intended for use by persons under 18 years of age or the applicable legal minimum age for consumption of the relevant Products.

We do not knowingly collect Personal Data from persons under 18 years of age.

Your rights of access, rectification, erasure, restriction and data portability

You have the right to receive an overview of your Personal Data processed by us or on our behalf. You have the right to have your data rectified, erased or restricted where applicable.

You can exercise this right by contacting service@beerwulf.com.

Please note that requests that do not meet the requirements of applicable law or BEERWULF guidelines may need to be resubmitted or may ultimately be rejected, and that certain Personal Data may be exempt from such access, rectification and erasure requests under 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 in certain circumstances we will transmit your data to another controller at your request where technically feasible.

Your right to object

In certain circumstances, you also have the right to require us to stop processing your Personal Data. However, if we have compelling legitimate grounds, we will continue processing your Personal Data.

You have the right to object to our use of your Personal Data for direct marketing purposes, including profiling, and if you do so, we will comply with your request.

Where you have given consent to the use of your Personal Data, you have the right to withdraw your consent without affecting the lawfulness of our use of that data before your withdrawal.

Updates

We will review this Privacy Policy regularly and update it from time to time.

Any changes to this Privacy Policy will be published on our Website and communicated to you where reasonably possible.

Contact

If you have any questions, objections to our use of your Personal Data, or a complaint about this Privacy Policy or our handling of your Personal Data, you can email service@beerwulf.com.

You also have the right to lodge a complaint with your local data protection authority.