1. General

This Privacy Policy applies to our website dedicated to our brand Edelweiss beer, available at https://www.edelweissbeer.com (the "Website") where we, Heineken International B.V. located at Tweede Weteringplantsoen 21, 1017 ZD Amsterdam, the Netherlands (‘we’ or ‘us’) collect certain personal data. We are part of the HEINEKEN Group. We are the controller of the Personal Data collected and processed through this website.

Please read this Privacy Policy carefully as it contains important information to help you understand our practices regarding any personal information that you give to us or that we collect otherwise in the context of the Website (“Personal Data”).

2. What Personal Data We Collect and How We Use your Personal Data

You can use the majority of our Website without being required to provide any Personal Data to us. For certain services or activities you will need to provide Personal Data for us to be able to provide you the requested service or product or for you to participate in the activity. Requested information on the Website marked with an asterisk is mandatory. If you do not provide the requested information, we will not be able to deliver the service or product to you or you cannot participate in the activity. In addition to information you are required to provide to us in order to participate in activities/campaigns, we collect certain information when you visit our Website.

• information about your visit to and use of our Website

We collect certain information when you visit our Website, such as your IP address, which web pages you visit, device category, browser, and type of internet browser, social media activity (such as Twitter, LinkedIn, Google, Facebook & Instagram), clicks and views. The information about your use of our Website and services enables us to build segments, which are groups of website visitors or customers with a number of 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 customize the Website and to e.g. change the order of search results or where we place certain offers so you are more likely to see these but also to personalise Website content so these may be tailored to your preferences. We may also use segments to show online advertisements that we think are relevant for you.

We use this Personal Data as it is necessary in our legitimate interests to do so to promote our products and services to our website visitors, to maintain the relevance of our brands and reputation, to enable us to attract more website visitors and to grow business by serving website visitors with advertising relating to our brands and to finance our Website (via online advertisements). We will retain the Personal Data for 24 months after your last relevant activity on our Website. We will ask for prior consent, when we are legally required.

• maintenance and optimisation of our Website

Your Personal Data will also be used for maintenance and analysis of our Website to solve performance issues, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, to improve the availability and user experience of the Website and to secure the Website against fraud. We log all use of our Website.

Our use of your Personal Data for these purposes is necessary in our legitimate interests and the information will be retained for a maximum period of 14 months. The logs of the use of our Website will be deleted within 14 months after creation.

• using photo and /or video footage

The Personal Data may include photo and/ or video footage captured at public or private events on social media, with marketing agencies and internally. We may share these photos and video footage on our Website or use social media to promote our products and brands and grow our business. Where required by law, we will first obtain your consent to use this data. We will retain the data for 6 years from the time the photo or video recording was captured.

• strategic reporting purposes, creating insights and marketing activation

The Personal Data collected by us is used to create aggregated strategic reports with insights and for sending commercial messages and personalized marketing (as described under the relevant purposes above), which are used to identify opportunities globally and to improve our global brands, products and services.

We use this information as it is in the legitimate interest of the HEINEKEN Group and all affiliates and subsidiaries to identify opportunities globally and to promote and improve our products and services to our customers and website visitors and to maintain the relevance of our brands and reputation. We will retain this information for 24 months. We will ask for prior consent, when we are legally required.

3. How We Share Your Personal Data

As member of a global business, we share Personal Data within the HEINEKEN Group, with affiliates and subsidiaries and also receive Personal Data from our affiliates and subsidiaries for reasons as aggregated analytical and operational purposes and for market activation as further described under 2. in this Policy. We will only share or receive such Personal Data and cookie data when we are allowed to do so by law. This means that you will be asked for prior consent, if this should be the lawful basis (for example when we share cookie data). When we are allowed to rely on our legitimate interest, we will do so. This is the case when we create and share aggregated marketing insights or segments. 

We may need to share Personal Data with third parties to help us provide services and products to you and to run our Website. These third parties are:

• HEINEKEN group companies for the purpose of storing Personal Data processed via the Website, due to shared IT systems
• service providers where this is needed to provide us with a service and to provide data analytics services
• service providers that help us organize campaigns and promotions
• first and third party advertising companies
• media agencies for marketing purposes and research purposes
• social media providers
• HEINEKEN group companies in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings)
• in case HEINEKEN sells all or some of the assets or shares of a HEINEKEN group company to which Personal Data was transferred to a third party, your Personal Data may be provided to this third party.

These parties may be located in the European Union or other countries in the European Economic Area or elsewhere in the world.  When Personal Data is stored by us outside the EEA we will ensure an adequate level of protection of the transferred Data. We require service providers to use appropriate measures to protect the confidentiality and security of the Personal Data.

We may also need to provide Personal Data to law enforcement bodies in order to comply with any legal obligation or court order.

4. Security of Personal Data

We will take appropriate technical, physical and organizational measures to protect the Personal Data collected through the Website from misuse or accidental, unlawful or unauthorized destruction, loss, alteration, disclosure, acquisition or access, that are consistent with applicable privacy and data security laws and regulations. However, no internet-based site 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 such other websites, which shall not be governed by this Privacy Policy. We advise you to always carefully read the privacy policies on these other websites.

5. Retention of Your Personal Data

We will retain your Personal Data for as long as legally required or for as long as necessary to provide you with any requested services or for any of the other purposes listed in this Privacy Policy. The specific retention terms are listed in this Privacy Policy for each of the relevant purposes. We will take reasonable steps to destroy or de-identify Personal Data we hold if it is no longer needed for the purposes set out above or after the expiration of the defined retention term.

6. Cookies

A major part of the information referred to in this Privacy Policy is collected via our use of cookies and similar techniques. Cookies are small text files containing small amounts of information which are downloaded and may be stored on your user device, e.g. your computer, smartphone or table. Techniques we use that may be similar to cookies are tracking pixels, Java scripts, tags and web beacons. These cookies and similar techniques are sometimes necessary to remember your account settings, language and country, but also enable us to measure and analyse your behaviour on our Website and for showing you personalised advertisements on our Website or on third party websites. Where required, you will be asked for consent to our use of cookies. To view more information on what cookies we use and how we use them please review our separate Cookie Policy, which is also available in the footer of this Website.

7. Social Media

You may choose to share information on our Website via social media, such as Facebook, Instagram, LinkedIn and YouTube. This means that the information you share, with name and preferences, shall be visible to visitors of your personal pages. We advise you to carefully read the privacy policies of the social media parties as these are applicable to the processing of your Personal Data by these parties.

8. Children's Privacy

The Website is not intended for use by individuals under the age of 18 (or the applicable legal 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, Deletion, Restriction and Data Portability

If your personal data is or has been subject to the European GDPR (General Data Protection Regulation) or to the extent applicable under your local law, you have the right to request access to and deletion of your personal data, to request restricted processing, to receive an overview of the personal data that you have provided to us in a structured, commonly used and machine-readable format. You also have the right to file a complaint with your local data protection authority. All your rights are subject to applicable data protection laws and other relevant laws and regulations, to the HEINEKEN Privacy Procedures and other HEINEKEN guidelines.  Where you have provided consent to our use of your Personal Data, you have the right to withdraw your consent without this effecting the lawfulness of our use of this Data before your withdrawal. 

Please note that if you make use of (some of) your choices and rights, you may not be able to use, in whole or in part, our Website services anymore. 

10. Your Right to Object

You also have a right, in certain circumstances, to require us to stop processing your Personal Data, but where we have compelling legitimate grounds, we will continue processing your Personal Data. However, you have the right to object to our use of your Personal Data for direct marketing purposes, including profiling, and when you do so, we will accommodate your request. 

11. Updates

We will keep this Privacy Policy under review and make updates from time to time. Any changes to this Privacy Policy will be posted on our Website page and to the extent reasonably possible, will be communicated to you.

12. Contact

If you wish to exercise any of your rights listed above, if you have any other question or a complaint about this Privacy Policy or about our handling of your Personal Data, please contact us via this web form. You also have the right to file a complaint with your local data protection authority.

This policy serves as a written notice ("Notice") as prescribed under the Personal Data Protection Act 2010 (hereinafter referred to as the "PDPA"), to inform you that your personal data is being processed by or on behalf of Heineken Marketing Malaysia Sdn Bhd ("HMMSB", "our", "us" or "we"). For the purpose of this Notice, the terms "personal data", "sensitive personal data" and "processing" shall have the meaning prescribed in the PDPA.

We are collecting and further processing the personal data you choose to share on Facebook, Instagram, Twitter, YouTube, and other social media sites, including our brand website (collectively, “Social Media Sites”). The personal data collected and further processed by us may vary between individuals depending on the privacy and security settings available to your account on the relevant Social Media Sites. For more information about the choices and means for limiting the personal data processed by the Social Media Sites, please visit the respective Social Media Sites privacy policy page.

We will be processing your personal data, including any additional information you may subsequently provide to us, for the purposes of contacting or communicating with you, advertising our or third party’s services, products, activities, special events or offers, to respond to your posts, submissions, comments, requests, inquiries or complaints, to request feedback from you, assessing your application to register for the use or subscription of the Website, [to provide services to you], administer your participation in contests, conduct internal activities, market surveys and trend analysis, other legitimate business activities of HMMSB, and any other purposes as may be related to the foregoing [and/or as set out in the Social Media Sites and if applicable, contest terms and conditions] (collectively, the “Purposes”).

In respect of the personal data collected from our brand website, it is obligatory that you supply us your name, date of birth, contact details, any information that you enter on forms and any personal data included in content you upload on the site. If you choose not to provide us the compulsory personal data, we may not be able to process your personal data for any of the Purposes.

By “liking” our Facebook brand page, or following us on our brand’s Instagram or Twitter, or subscribing to our brand’s YouTube channel or by submitting your personal data through the registration page of our brand website or otherwise expressing or providing a similar indication of your interest in us in other Social Media Sites, you hereby agree that you have read this Notice and consent to our collection and further processing of your personal data in the respective Social Media Sites in the manner as specified in this Notice. Unless you have asked us not to, we will contact you by posting, messaging or emailing you with any offer or promotions in relation to our upcoming events, products and services. If you do not wish to receive any of these offers or promotions, or wish to make a data access request, data correction request, to limit the processing of your personal data, or to contact us with any enquiries or complaints in respect of your personal data, you may do so to:

Designation:Brand Manager
Telephone No.:(603)7861 4688
E-mail address: edelweiss.msia@gmail.com

You are responsible for ensuring that the personal data we collect is accurate, complete, not misleading and kept up to date.

This Notice shall be drafted in English as well as in Bahasa Malaysia. In the event of any inconsistency between the English version and the Bahasa Malaysia version of this notice, the English version shall prevail over the Bahasa Malaysia version.