Privacy Policy

1. General

This Privacy Policy applies to the BEERWULF e-commerce platform and services for consumers, accessible at https://www.beerwulf.com (the “Website”), where we, Beerwulf B.V. (Stadhouderskade 80, 1073 AT Amsterdam, The Netherlands) (“Beerwulf”), collect certain personal data. 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 personal data that you provide to us or that we otherwise collect in connection with your use of the Website and the services provided there (“Personal Data”). Beerwulf (“we” or “us”) is the data controller for 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 obligations under applicable data protection laws.

2. 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 any personal data. However, 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 you newsletters or other information. In addition to the personal data you are required to provide, we collect certain information when you visit our website, such as cookies; see section 6 below.

We have specified what personal data we collect, for what purposes we use personal data, and how long we generally retain your personal data:

1) Processing your order to complete your payment and provide you with the requested product or service: We need your name, email address, telephone number (in case we need to contact you regarding your order), your postal address or that of another recipient of the order, and payment information.

The use of this personal data is necessary for the performance of our contract with you or for compliance with legal obligations, such as tax and accounting regulations. We retain our online sales records for 6 years or longer if required by tax or commercial accounting obligations.

2) Registering and creating an account on our website: When you place an order on our website, you can create a customer account or complete your purchase as a guest. If you choose to create an account, you will need to provide your name, email address, shipping and billing address, payment information, and phone number. We also store transaction data, i.e., your order history and related transaction details.

If you choose to pay as a guest, i.e., without creating a customer account, we still require certain information from you to process and deliver your order. This information includes your name, email address, shipping and billing address, payment information, and phone number. However, you will not need to create a password. We will still store transaction data, i.e., your order history and related transaction details.

If, at a later date after making one or more purchases, you decide to create a customer account and place another order, we may link this order to the contact details you previously provided for guest orders. We do this to avoid data duplication and to ensure we can process your order. If you do not want us to retain this data, you can request its deletion by contacting us; see section 9 below.

We retain personal data for as long as necessary to fulfill the purposes for which it was collected. Customer data is retained after the date of the customer's last order in accordance with applicable laws and regulations.

3) Customer Service: For complaints or inquiries, you can contact us via the website, by email (service@beerwulf.com), or by phone at +44(0)8081899853. For customer service purposes, we process your email address, name, and/or phone number, depending on how you contact us. We record your requests, inquiries, complaints, as well as our responses and other actions necessary to address your request. Subject to your consent, we may record calls if you contact us by phone.

Beerwulf retains all information for two years after your question or complaint has been resolved or the inquiry has been closed.

4) Marketing: If you have subscribed to our newsletter, we will use the email address you provided to send you our newsletter ("opt-in"). If you have already placed an order with us, we may also send you newsletters to inform you about other similar products that may be of interest to you ("soft opt-in"). If you no longer wish to receive commercial communications from us, you can unsubscribe at any time using the unsubscribe link in any email or contact us directly.

We use this personal data to promote our products and services, increase sales, and maintain or improve our business relationship with you. We obtain your prior consent before sending commercial communications, unless soft opt-in applies. We retain personal data in accordance with the respective purposes for which it was collected (e.g., newsletters, marketing). Personal data is generally deleted or anonymized two years after your last order on our website.

5) Profiling and Personalization: We may combine information about your purchases, online searches and social media activity, clicks and views, your settings on our website, the items in your shopping cart, your customer service inquiries, and your contact history. This information allows us to use various channels for relationship management and direct marketing of our products to you, such as personalized emails, mailings, social media interactions, apps, or online advertising tailored to your preferences.

We use this personal data as necessary to protect our legitimate interests in promoting our products and services to our customers and website visitors, acquiring more customers, and improving our product sales. We will request prior consent where legally required to do so.

Personal data processed for (direct) marketing purposes will be retained after the date of the customer's last order in accordance with applicable laws and regulations.

6) Information about your visit to and use of our website: Using cookies and similar technologies, we collect certain information when you visit our website, such as your IP address, which pages within the website you visit, the type of internet browser you use, clicks and views, the type of device you use, and your operating system. We also record whether you have opened our newsletter and clicked on any links it contains. This information allows us to create segments, i.e., groups of website visitors or customers with several common characteristics, such as age group, category interests, or region. We may assign you to one of our segments. We may also use segments to display online advertisements or send emails that we believe are relevant to you.

We obtain your prior consent before using analytics or tracking cookies. Please also see section 6 below and our Cookie Policy for further information.

7) Website Maintenance and Optimization: Using cookies and similar technologies, some of the information we collect is used for website maintenance and analysis. This includes troubleshooting performance issues, improving availability, and protecting the website against fraud (e.g., repeated login or purchase attempts, or purchases made in violation of our Terms and Conditions, such as by individuals under 18). This analysis also allows us to verify the efficiency of the online ordering process so we can improve it where possible.

We obtain your prior consent before using performance cookies. Please also see section 6 below and our Cookie Policy for further information.

8) Participation in Research Activities: We may ask you to participate in research activities such as surveys, pilot projects, panels, focus groups, Net Promoter Score (NPS) surveys, and other research activities. Depending on the research activity, we will collect and potentially share various sets of (pseudonymized) personal data. Before participating in any research activity, you will always be informed about what personal data we collect, for what purpose we collect it, and whether (and to whom) we share this personal data.

Depending on the nature and characteristics of the research activity, we collect personal data for research purposes either based on your consent or our legitimate interest.

9) Enabling your participation in sweepstakes, contests, or other promotions: Certain personal data, such as your name, email address, and shipping address, will be processed to administer the sweepstakes, contests, or other promotions you wish to enter. Some of these promotions are subject to additional rules that provide information about how we use and disclose your personal data.

The use of this personal data is necessary for the performance of our agreement with you, which governs the sweepstakes, contests, or other promotions in which you participate.

3. How We Share Your Personal Data

As a subsidiary of a global company, we share personal data (e.g., name, email address, telephone number) and information we have collected via cookies or similar technologies (“cookie data”) with affiliated companies and subsidiaries of the HEINEKEN Group for aggregated analysis and operational purposes, (re)targeting, the development of predictive behavior models, the creation of consumer or look-alike audiences (where permitted by local law), and to enrich existing customer profiles. We only share such personal data and cookie data when permitted to do so by (local) law. This means that we request prior consent where this is the legal basis we use and rely on our legitimate interest where permitted, for example, when we gain insights from aggregated customer data to improve our marketing efforts.

We must share personal data with certain third parties. These third parties are service providers required to provide us with a service or (to help us) to provide or deliver the service or product you ordered on the website (including our external delivery service provider), as well as to provide data analytics services. The service providers we work with include:

• Our logistics and customer service partners, such as external logistics providers who handle order processing and delivery of our products, as well as ticketing systems for your inquiries.
• Payment service providers who act as "controllers" to receive and process payments you make through the website. Details about how these providers use your personal data can be found in their respective privacy policies.
• Furthermore, we may use, disclose, or transfer your information to a HEINEKEN Group company in the event of a restructuring, merger, sale, joint venture, assignment, transfer, or other disposition of all or part of our business, assets, or shares (including in connection with insolvency or similar proceedings).
• Independent debt collection agencies, lawyers, or other agents for the purpose of collecting amounts due or outstanding on your account.
• If HEINEKEN sells all or some of the assets or shares of a HEINEKEN Group company to which personal data has been transferred to a third party, your personal data may be transferred to that third party.
• Advertising companies, both first-party and third-party.
• Media 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, or other countries within the European Economic Area (“EEA”) or elsewhere in the world. When we transfer personal data outside the EEA, we ensure an adequate level of protection for the transferred personal data by guaranteeing 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 disclose personal data to law enforcement authorities to comply with a legal obligation or court order.

4. Security of Personal Data

We will implement appropriate technical, physical, and organizational measures to protect your personal data against misuse or accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, acquisition, or access, in accordance with applicable data protection and data security laws and regulations. However, no internet-based website or service can be 100% secure, and we cannot be held responsible for unauthorized or unintentional 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 measures of such other websites, which are not governed by this Privacy Policy. We encourage you to always carefully review the privacy statements on these other websites.

5. Retention of Your Personal Data

We retain your personal data for as long as required by law, or as long as necessary to provide you with requested services or to fulfill any of the other purposes outlined in this Privacy Policy. Specific retention periods are detailed in this Privacy Policy for each of these purposes. We will take reasonable steps to destroy or anonymize the personal data we hold when it is no longer needed for the purposes described above or when the specified retention period has expired.

6. Cookies

Some of the information mentioned 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. Similar technologies we use are called pixels, which can be used to track your interactions with the website. These cookies and similar technologies are sometimes necessary to store 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 advertising on our website or on third-party websites. Where necessary, you will be asked for your consent to our use of cookies. You can find more information about which cookies we use and how we use them in our separate Cookie Policy at https://beerwulf.com/pages/cookie-policy.

7. Social Media

You can 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 of your personal pages. We recommend that you carefully read the privacy policies of the social media providers, as these govern how they process your personal data.

8. Children's Privacy

This website is not intended for individuals under the age of 18 (or under the legal minimum 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, Erasure, Restriction of Processing, and Data Portability

You have the right to request an overview of your personal data that we process or that is processed on our behalf. You have the right to have your personal data rectified, erased, or its processing restricted (where applicable). You can exercise this right by contacting service@beerwulf.com. Please note that requests that do not comply with the requirements of applicable law or BEERWULF's policies may need to be resubmitted or may ultimately be rejected, and that certain personal data may be exempt from such requests for access, rectification, and erasure 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 under certain circumstances, we will transmit your personal data to another controller at your request, provided this is technically feasible.

10. Your Right to Object

You also have the right, under certain circumstances, to request that we stop processing your personal data. However, if we have compelling legitimate grounds, we may continue processing your personal data. You also have the right to object to our use of your personal data for direct marketing purposes, including profiling. If you do so, we will comply with your request. If you have consented to our use of your personal data, you have the right to withdraw your consent at any time, without affecting the lawfulness of our use of that personal data before you withdrew it.

11. Updates

We will continually review and update this Privacy Policy from time to time. Any changes to this Privacy Policy will be published on our website and communicated to you where reasonably possible.

12. Contact

If you have any questions, wish to object to our use of your personal data, or have a complaint regarding this Privacy Policy or our handling of your personal data, you can send an email to service@beerwulf.com. You also have the right to lodge a complaint with your local data protection authority.

Last updated: June 2025