Beerwulf Privacy Policy

1. General

This Privacy Policy applies to the BEERWULF e-commerce platform and consumer services available 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 the personal information you share with us or that we otherwise collect in connection with your use of the Website and the services provided through it (“Personal Data”). Beerwulf (“we”, “us” or “our”) is the controller of the Personal Data collected and processed.

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

2. What Personal Data do we collect and how do we use it?

You may use most of our Website without providing us with Personal Data. However, for certain services and functionalities of the Website, the provision of Personal Data is necessary. This is the case, for example, when we need to process your orders or send you newsletters and other information. In addition to the Personal Data you provide to us, we collect certain information during your visit to our Website, including through cookies; please refer to Section 6 below.

We have outlined the Personal Data we collect, the purposes for which we use it, and the period for which we generally retain it:

1) Processing your order

In order to process your payment and deliver the requested product or service, we require your name, email address, telephone number (in case we need to contact you regarding your order), postal address or the address of any other recipient of the order, and your payment information.

The use of this Personal Data is necessary for the performance of our contract with you, or to comply with legal obligations, such as tax and accounting requirements. Our online sales records will be retained for 6 years, or longer if required by tax or accounting regulations.

2) Registration and creation of an account on our Website

When placing an order on our Website, you may create a customer account or complete your purchase as a guest. If you choose to create an account, we will ask you to provide your name, email address, delivery and billing addresses, payment information, and telephone number. In addition, we retain transactional data, meaning your order history and the details of related transactions.

If you choose to place an order as a guest, meaning without creating a customer account, we will still ask you to provide certain information necessary to process and deliver your order. This information includes your name, email address, delivery and billing addresses, payment information, and telephone number. However, you will not be required to create a password. We will still retain transactional data, meaning your order history and the details of related transactions.

If, at a later stage and after making one or more purchases, you decide to create a customer account and place a subsequent order, we may link that order to the details previously provided for your guest orders. We do this to avoid duplication of data and to ensure that we can fulfil your order correctly. If you do not wish us to retain this data, you may request its deletion by contacting us; please refer to Section 9 below.

We retain Personal Data for as long as necessary to fulfil the purposes for which it was collected. Customer information will be retained in accordance with applicable laws and regulations from the date of the customer's last order.

3) Customer Service

If you have a complaint or enquiry, you may contact us through the Website or by email (service@beerwulf.com). For customer service purposes, we will process your email address, name and/or telephone number, depending on how you contact us. We record your enquiries, questions, complaints, our responses, and any other actions necessary to handle your request. Subject to your consent, we may record telephone calls when you contact us by phone.

Beerwulf will retain all such information for 2 years after your question or complaint has been resolved or your request has been closed.

4) Marketing

If you have subscribed to our newsletter, we use the email address you provided to send you our newsletter ("opt-in"). If you have previously placed an order with us, we may also send you newsletters informing you about similar products that may be of interest to you ("soft opt-in"). If you no longer wish to receive marketing communications from us, you may unsubscribe at any time using the unsubscribe function included in each email, or by contacting us directly.

We use this Personal Data to promote our products and services, improve sales, and maintain or enhance our business relationship with you. We will obtain your prior consent before sending you marketing communications, except where a "soft opt-in" applies. We will retain Personal Data in accordance with the relevant purposes for which it was collected (e.g. newsletters, marketing). Personal Data will generally be deleted or anonymised two years after your last order on our Website.

5) Profiling and Personalisation

Information about your purchases, online searches and social media activity, clicks and views, preferences on our Website, items in your shopping basket, customer service enquiries, and contact history may be combined by us. This information allows us to use various channels for customer relationship management and direct marketing of our products to you through personalised emails, postal mail, social media interactions, applications, or online advertising tailored to your preferences.

We use this Personal Data because it is necessary for our legitimate interests in promoting our products and services to customers and visitors of our Website, attracting new customers, and improving sales of our products. We will obtain your prior consent where we are legally required to do so.

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

6) Information About Your Visit to and Use of Our Website

Through cookies and similar technologies, we collect certain information when you visit our Website, such as your IP address, the webpages you visit, the type of internet browser you use, clicks and views, the type of device you use, and your operating system. We also track whether you have opened our newsletter and clicked on any links contained within it. This information allows us to create segments, meaning groups of Website visitors or customers who share common characteristics such as age group, interests, or region. We may assign you to one of these segments. We may also use segments to display online advertisements or send emails that we believe are relevant to you.

We will obtain your prior consent before using analytical or tracking cookies. Please also refer to Section 6 below and our Cookie Policy for further information.

7) Maintenance and Optimisation of Our Website

Using cookies and similar technologies, some of the information we collect is used to maintain and analyse our Website in order to resolve performance issues, improve availability, and protect the Website against fraud (for example, repeated login or purchase attempts, or purchases made in breach of our Terms and Conditions, such as by persons under the age of 18). Analysis also enables us to verify whether the online ordering process is functioning effectively so that improvements can be made where possible.

We will obtain your prior consent before using performance cookies. Please also refer to Section 6 below and our Cookie Policy for further information.

8) Participation in Research Activities

We may invite you to participate in research activities such as surveys, pilot projects, panels, focus groups, Net Promoter Score (NPS) surveys, and other research initiatives. Depending on the research activity, we may collect and share different sets of (pseudonymised) Personal Data. You will always be informed before the research activity of the Personal Data we will collect, the purpose of the collection, and whether (and with whom) we will share such Personal Data.

Depending on the type and nature of the research activity, we will collect Personal Data for research purposes either on the basis of your consent or on the basis of our legitimate interests.

9) Participation in Prize Draws, Competitions and Other Promotions

Certain Personal Data, such as your name, email address and delivery address, will be processed in order to administer prize draws, competitions or other promotions in which you choose to participate. Some of these promotions may be subject to additional rules that contain information about how we will use and disclose your Personal Data.

The use of this Personal Data is necessary for the performance of our agreement with you governing the prize draw, competition or other promotion 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 obtained through cookies and similar technologies ("Cookie Data") with HEINEKEN Group affiliates and subsidiaries for aggregated analytical and operational purposes, (re)targeting, behavioural prediction modelling, the creation of consumer audiences or lookalike audiences (where permitted under local law), and the enrichment of existing customer profiles.

We will only share such Personal Data and Cookie Data where permitted by applicable (local) law. This means that we will obtain your prior consent where this is the legal basis on which we rely, and we will rely on our legitimate interests where permitted to do so, for example when generating insights from aggregated customer data in order to improve our marketing activities.

We are required to share Personal Data with certain third parties. These third parties are service providers that are necessary to provide services to us or to help us provide or deliver the service or product you have ordered through the Website (including our third-party delivery provider), as well as providers of data analytics services. The service providers we work with include:

• Our logistics and customer service partners, such as third-party logistics providers responsible for the preparation and delivery of our products, and ticket management systems used to process your enquiries.
• Payment service providers acting as independent controllers for the collection and processing of payments made through the Website. Details of how these providers use your Personal Data can be found in their respective privacy policies.

In addition, we may use, disclose or transfer your information to another HEINEKEN Group company in the event of a reorganisation, merger, sale, joint venture, assignment, transfer or other disposal of all or part of our business, assets or shares (including in connection with bankruptcy or similar proceedings).

We may also share your Personal Data with:

• Independent debt collection agencies, lawyers or other representatives for the purpose of recovering amounts due or outstanding on your account.
• A third party in the event that HEINEKEN sells all or part of the assets or shares of a HEINEKEN Group company to which your Personal Data has been transferred.
• Internal and third-party advertising networks.
• Media agencies for marketing and research purposes.
• Social media providers, such as Facebook, Instagram and 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. Where Personal Data is transferred outside the EEA, we will ensure that an adequate level of protection is applied to the transferred Personal Data by implementing the appropriate legal safeguards.

We require our service providers to use appropriate technical and organisational measures to protect the confidentiality and security of Personal Data.

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

4. Security of Personal Data

We will take appropriate technical, physical and organisational measures to protect your Personal Data against misuse and against accidental, unlawful or unauthorised destruction, loss, alteration, disclosure, acquisition or access, in accordance with applicable privacy and data security laws and regulations. However, no website or internet-based service 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 those other websites, which are not governed by this Privacy Policy. We recommend that you always read the privacy policies of those other websites carefully.

5. Retention of Your Personal Data

We will retain your Personal Data for as long as required by law or for as long as necessary to provide you with the requested services or for any other purpose set out in this Privacy Policy. Specific retention periods are stated in this Privacy Policy for each relevant purpose. We will take reasonable steps to destroy or anonymise the Personal Data we hold if it is no longer required for the purposes set out above or after the applicable 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 are downloaded and may be stored on your device, such as your computer, smartphone or tablet. The similar technologies we use include so-called “pixels”, which may 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 analyse your behaviour on our Website and to show you personalised advertisements on our Website or on third-party websites. Where applicable, your consent will be requested for the use of our cookies. For more information about the cookies we use and how we use them, please see our separate Cookie Policy at https://beerwulf.com/pages/cookie-policy.

7. Social Media

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

8. Children’s Privacy

The Website is not intended for use by persons under the age of 18, or under the applicable legal age for consuming the relevant products. We do not knowingly collect Personal Data from persons under the age of 18.

9. Your Rights of Access, Rectification, Erasure, Restriction and Data Portability

You have the right to request an overview of the Personal Data processed by us or on our behalf. You have the right to have your Personal Data rectified, erased or restricted, where applicable. You may exercise this right by contacting service@beerwulf.com. Please note that you may be asked to reformulate requests that do not meet the requirements set by applicable law or BEERWULF guidelines, or such requests may ultimately be rejected. In addition, certain Personal Data may be exempt from such access, rectification and deletion requests 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, in certain circumstances, we will transfer your Personal Data to another controller at your request where technically feasible.

10. Your Right to Object

You also have the right, in certain circumstances, to require us to stop processing your Personal Data. However, where we have compelling legitimate grounds, we may continue to process it. You nevertheless have the right to object to the 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 consented to the use of your Personal Data, you have the right to withdraw your consent without affecting the lawfulness of the use of such data before your withdrawal.

11. Updates

We will regularly review this Privacy Policy and update it from time to time. Any changes to this Privacy Policy will be published on the relevant page of our Website and, where possible, communicated to you.

12. Contact

If you have any questions, objections regarding our use of your Personal Data, or a complaint concerning this Privacy Policy or our processing 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