• the personal data relating to you that we collect; 
• how we use this personal data; 
• the legal basis upon which we process it;
• with whom it is shared; and 
• how it is stored. 

1. your name;
2. your job title;
3. company name;
4. e-mail address;
5. your telephone number; 
6. account information; 
7. your company's address;
8. your gender;
9. your date of birth; 
10. data provided when you correspond with us;
11. any updates to data provided to us; and
12. if you attend our sites, CCTV footage.
     

1. if you visit our website, your IP address;
2. your user name;
3. your age /date of birth;
4. your behaviour on our website (for example, the pages that you click on) 
5. payment details; 
6. order history; and
    

1. data needed to provide goods or services to you (including data on account opening forms, details of your order, volume of our beers ordered from our appointed Distributor,  order history, payment details, delivery address, delivery requirements and restrictions, trade references and tax information);
2. the name you give us for personalised products;
3. customer services data; and
4. customer relationship management and marketing data.
    

1. your photo and video footage if you are a collaborator or brand ambassador, or a potential collaborator or brand ambassador;
2. CVs, pitch and tender data; and white paper data;
3. supplier due diligence data 
4. work contact data (phone number, postal address, mailing address, email address);
5. address;
6. visa or work permit documentation;
7. emergency contact data;
8. work hours (overtime and shift work, hours worked and department standard hours);
9. details of compensation, expense claims and bank details;
10. court, tribunal and inquiry proceedings (relevant to your work for us); and 
11. data required to access company systems and applications..
     

1. technical data, including the Internet protocol (IP) address used to connect your device to the internet, domain name and country which requests data, the files requested, browser type and version, browser plug-in types and versions, operating system and platform; 
2. data about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time), time and length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and data provided when requesting further service or downloads.
    

1. to allow you to access and use our website (including to ensure you are of legal drinking age);
2. to provide technical support;
3. to provide you with the information and services that you request from us;
4. to ensure the security of our services, our website;
5. to store information about your preferences, and to allow us to customise our websiteaccording to your individual interests;
6. to recognise you when you return to our website;
7. to enable you to participate in our competitions and promotions; 
8. to process orders which you place for goods or services from us; and
9. for improvement and maintenance of our website and preparing reports or compiling statistics in order to improve our goods and services. Such details will be anonymised as far as is reasonably possible and you will not be identifiable from the data collected.

1. to enable us to receive and manage services from you (including supplier due diligence, payment and expense reporting and financial audits);
2. to confirm information on CVs and performance reference checks, to assess you or your employer's suitability to work for us; 

1. to provide relevant goods or services to you or your employer (including, to confirm and process orders, for administration of your account with us, customer loans, tax and export, billing and debt collection purposes and the collection of bottles (where applicable));
2. to deal with any enquiries or issues you have about our goods and services, including any questions you may have about how we collect, store and use your personal data, or any requests made by you for a copy of the data we hold about you. If we do not have a contract with you, we may process your personal data for these purposes where it is in our legitimate interests for customer services purposes;
3. to send you certain communications (including by email or post) about our goods and services such as service announcements and administrative messages (for example, setting out changes to our terms and conditions and keeping you informed about our fees and charges);
4. to allow you to attend our events or participate in competitions and to send you photos that you have permitted us to take of you;
5. to carry out statistical analysis and market research; and
6. if you have consented or, otherwise, if it is in our legitimate interests, for business development and marketing purposes, to contact you (including by email or post) with information about our products and services which either you request, or which we feel will be of interest to you (including newsletters), but only, if required by law if you have consented to this.

3. Legal basis for use of your personal data

1. our use of your personal data is necessary to perform our obligations under any contract with you and/or in order to take steps at you request prior to entering into a contract (for example, to fulfil and order which you place with us, to comply with the terms of use of our website or software app to be able to make use of our software app  and/or to comply with our contract to provide services to or receive services from you or your employer); or
2. our use of your personal data is necessary for complying with our legal obligations (for example, providing information to HMRC); or
3. where neither (1) nor (2) apply, use of your personal data is necessary for our legitimate interests (including Asahi Group) or the legitimate interests of others for example, to ensure the security of our website. Our legitimate interests are to:

1. run, grow and develop our business;
2. operate our website;
3. select appropriately skilled and qualified suppliers;
4. ensure a safe working environment for our staff and visitors;
5. marketing, market research and business development;
6. provide goods and services to our customers, make and receive payment, provide customer services and to know the customer that we are providing services to; 
7. place, track and ensure fulfilment of orders with our suppliers; and
8. for internal group administrative purposes of Asahi Group, as described in section 5.1 below.

4.1 - Some pages on our website use cookies, which are small files placed on your device  when you visit our website. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.

4.2 - Where we use cookies on our website, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our website or to use all the functionality provided through our website.

5.1 - We may share your personal data with any company that is a member of our group which includes our ultimate parent company based in Japan where it is required for our legitimate interests to do so for internal administrative purposes (for example, ensuring consistent and coherent delivery of services to our customers, corporate strategy, compliance, auditing and monitoring, research and development and quality assurance). We may also share your personal data with our group where they provide products and services to us as “processors”, such as information technology systems.  

5.2 We will share your personal data with the following categories of third parties:

1. our service providers and sub-contractors, including but not limited to payment processors, suppliers of technical and support services, insurers, logistic providers, and cloud service providers; 
2. your employer or recruitment agency; 
3. retailers and wholesalers, where you are a customer, provided such is to perform our obligations under any contract with you;
4. public agencies (including customs officials);
5. companies that assist us in our marketing, advertising and promotional activities; and
6. analytics and search engine providers that assist us in the improvement and optimisation of our website and our software apps.
    

1. where it is in our (including Asahi Group) legitimate interests to do so to run, grow and develop our business:
   1. if we sell or buy any business or assets, we may disclose your personal data to the seller or buyer of such business or assets;
   2. if substantially all of our or any of our affiliated companies' assets are acquired by a third party, in which case personal data held by us will be one of the transferred assets;
2. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;
3. in order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or
4. to protect the rights, property, or safety of Asahi Group our staff, our customers or other persons. 
    

7.1 - You have certain rights in relation to your personal data. If you would like further information in relation to these or would like to exercise any of them, please contact us by email at mkt@grolsch.nl at any time. You have the right to request that we:

1. provide access to any personal data we hold about you;
2. update any of your personal data which is out of date or incorrect;
3. delete any personal data which we are holding about you; 
4. restrict the way that we process your personal data;
5. prevent the processing of your personal data for direct-marketing purposes;
6. provide you with a copy of any personal data which we hold about you; or
7. consider any valid objections which you have to our use of your personal data.
   ​

7.2 - We will consider all such requests and provide our response within a reasonable period (and in any event any time period required by applicable law). Please note, however, that certain personal data may be exempt from such requests in certain circumstances.  

7.3 - If an exception applies, we will tell you this when responding to your request.  We may request you provide us with information necessary to confirm your identity before responding to any request you make.  

8.1 - We may collect and use your personal data to send you certain marketing communications (including electronic marketing communications to existing customers) if it is in our legitimate interests to do so for marketing and business development purposes.  

8.2 - However, we will always obtain your consent to direct marketing communications where we are required to do so by law.

8.3 - If you wish to stop receiving marketing communications, you can contact us by email at mkt@grolsch.nl at any time or by calling our free telephone number 0800 7770888 during business hours, and we will stop doing so.

9.1 - The personal data may be used, stored and/or accessed by staff operating outside the EEA working for us, other members of our group or Third Parties . This may be for the purposes listed in section 2 above, including but not limited to the provision of our services to you or your employer, the receipt of services from you or any of our Third Parties, the processing of transactions and/or the provision of support services. Further details on to whom your personal data may be disclosed are set out in section 5 above.

9.2 - If we provide any personal data about you to any such non-EEA members of our group or Third Parties, we will take appropriate measures to ensure that the recipient protects your personal data adequately in accordance with this Privacy Policy.  These measures include, but are not limited to:

1. in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further https://www.privacyshield.gov/welcome); or
2. in the case of entities based in other countries outside the EEA (including Japan), entering into European Commission approved standard contractual arrangements with them.

12.1 - If you have any queries or complaints about our collection, use or storage of your personal data, or if you wish to exercise any of your rights in relation to your personal data, please contact mkt@grolsch.nl. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal data.

12.2 - You may also make a complaint to the data protection authority in the European Union country where we are based, which is the “Autoriteit Persoonsgegevens” in the Netherlands, or where we process personal data that relates to offering goods or service to you in the European Union.   Alternatively you may seek a remedy through local courts if you believe your rights have been breached.