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Privacy Policy

This website is operated by Asahi UK Ltd (trade name: Asahi France), a foreign limited liability company registered in Paris under number 821 560 760, part of Asahi Group Holdings, Ltd.

All references to "Asahi," "our," or "we" in this policy refer to Asahi UK Ltd. or Asahi Group Holdings, Ltd. or its subsidiaries, affiliates or associates who may provide services to us.

We want to protect the privacy of those who provide us with personal data. This policy applies to our customers, staff who work for our customers, visitors to our websites, consumers, distributors, our current and potential suppliers, staff of such suppliers and subcontractors. It describes :

the personally identifiable information we collect;
how we use this data;
the legal basis used to process these data;
with whom we share them; and
as they are stored.

This policy also describes other important topics related to your data and their protection.

Please read this Privacy Policy carefully to understand how we manage your personal data.

By accessing or browsing our websites, contacting us on social networks, working with or for us, offering us your goods or services, using the goods and services we provide to you or otherwise transmitting data (including participating in competitions or attending our brewery or other events), you confirm that you have read and understood this entire Privacy Policy.

The Policy consists of the following Sections:

Section 1: Data Collection

Section 2: Use of Data

Section 3 : Legal bases used to process your personal data

Section 4 : Cookies

Section 5 : Disclosure of personal data

Section 6 : Retention of personal data

Section 7: Your Rights

Section 8 : Marketing

Section 9 : Data Transfers

Section 10 : Security

Section 11 : Third Party Websites

Section 12: Changes to our Privacy Policy

Section 13 : Other questions and claims

data collection

We may receive data about you directly from you. However, we may also receive data about you from third parties, such as your employer or recruitment agency, vendors of which you are a customer, media agencies, market research companies, our suppliers, group companies, public websites, agencies (including booking agents) and public bodies (including customs officials), which we refer to throughout this policy as "Third Party Sources".

We, or third parties on our behalf, may collect and use all of the following data about you and we refer to it as "Personal Data" throughout this policy:

Personal data that you provide to us (or that we receive from Third Party Sources).

You or your employer or recruitment agency may provide us with personal data about you by using the online forms provided on our websites, by completing order forms, by setting up an account with us or by contacting us by telephone, e-mail or other means. This includes when you or your employer provides us with your personal data in order to receive our services. You or our Third Party Sources may also provide us with personal information about you when you or such Third Party Sources offer or provide services to us.

Personal data that you give us (or that we receive from Third Party Sources) may include :

Information about you :

your name;
your position;
the name of the company ;
your e-mail address ;
your telephone number;
your account information;
the address of your company ;
your sex;
your date of birth;
data provided when you correspond with us;
any updates to the data transmitted; and
if you are present on our sites, video surveillance recordings.

Data about visitors to our websites and users of our software applications (as applicable):

if you visit our website, your IP address;
your username ;
your age;
your behaviour on our website (e.g. pages clicked) or on our software application;
payment details ;
order history; and
if you are a user of a mobile application, your location data which enables us to help you locate our products and services and, if you are a service provider, which enables us to monitor the effectiveness of the services you provide to us.

Information about the goods or services we provide to you:

data required to provide the goods or services to you (including data provided in account opening forms, order details, order history, payment details, delivery address, delivery requirements and restrictions, transaction references and tax information);
the name you give us for customized products; (iii)customer service data; and

(iv) customer relationship management and marketing data.

Information about the services we receive from you or your employer (including breweries, bars, wholesalers, restaurants, media contacts, transportation companies, warehouses, fulfillment centers, technical support equipment suppliers and engineers, brand ambassadors and other subcontractors):

your website ;

your photo and video recordings if you are a current or potential collaborator or ambassador;
CV data, pitch and tender data, and white paper data ; (iv)audit data from suppliers (e.g., alcohol wholesalers) ;

business contact information (telephone number, postal address, e-mail address) ;
proof of identity and address ;
visa or work permit ;
emergency contact information ;
data on accidents at the workplace ;
hours of work (overtime and shift work, hours worked and standard hours of service) ;
information on remuneration, expense reports and bank details ;

court proceedings and investigations; and
information required to access the company's systems and applications (e.g. a system identifier).

If you use our photo booth at one of our breweries or events, your photo and time stamp.

If you choose to use social networks to contact us or learn more about our products or services, your profile data (including your preferences and interactions with us on Facebook, Instagram and Twitter) and data you post on our forums that is relevant to our business.
If you participate in our events, your photo and video recording of the event (we will inform you of this at the event).

Some of the personal data that we collect about you or that you or third parties (including your employer or recruitment agency) provide to us may be considered special categories of data.

Please note that we require certain types of personal data in order for us to provide services to you or for you or our Third Party Sources to provide services to us. If you do not provide us with this type of personal data, or if you ask us to delete it, you will probably no longer be able to access or provide us with our goods or services.

Personal Data that we collect about you or that we obtain from our Third Party Sources.

Once you visit our websites, we may automatically collect the following types of data:

technical data, including the Internet Protocol (IP) address used to connect your computer to the Internet, the domain name and country requesting the data, the files requested, the type and version of browser used, the types and versions of browser plug-ins, the operating system and platform ;

data about your visit, including click stream on hyperlinks (URLs) to, via and from our site (including date and time), time and duration of visits to certain pages, page interaction data (e.g. scrolling, clicks and mouse hovers), methods used to leave the page, traffic data, location data, weblogs and other communication data and data provided when requesting other services or downloads.

If you contact us on social networks, we will collect certain data about you from your social network page and through your interactions with us or with data about our products and services.
If you are a journalist or work for a professional institution/association in our sector, we may collect data about you from public sources.
If you are an existing or potential customer or supplier, or work for one of them (including as a consultant), we may obtain data about you from your company's website.

If you work for us or visit one of our sites (for example, a brewery), we may also collect personal data about you via our video surveillance equipment.

Use of data

We, or our Third Party Sources acting on our behalf, collect, use and store the above personal data for the following purposes:

Visiting our websites or, if you are a consumer, using one of our software applications

allow you to access or use our website or the Application (including ensuring that you are of legal drinking age);
provide technical assistance ;
to provide you with the information and services you request from us;
ensure the security of our services, websites and application;
store information about your preferences, and allow us to customize our websites and the application according to your interests;
recognize you when you return to our websites;
if you are a user of the Application, to recognize your location to enable the Application to operate by providing you with directions to nearby bars, to monitor the use of the Application and the consumption of beer, to conduct market research and to understand your preferences and experience in places selling our products (e.g., a hotel, bar or restaurant);
allow you to participate in our contests and promotions;
process orders you place for our goods and services; and
to improve and maintain our websites and the Application and to prepare reports or compile statistics in order to improve our goods and services. These details will be anonymised to the extent reasonable and you will not be identifiable from the data collected.

Receiving goods and services from you

enable us to receive and manage your services (including, supplier audit, payment and expense reports and financial audits);
safety records and their management ;

assess your work capacity;

confirm CV information and conduct reference checks, in order to assess your suitability or that of your employer to work for us; and

Providing goods and services

provide the relevant goods or services to you or your employer (including confirming and processing orders, managing your account with us, customer loans, for tax and export billing and debt collection purposes, and bottle collection [if applicable]);
to manage your requests or problems with our products and services, including any questions about how we collect, store and use your personal data, or any request for you to obtain a copy of the data we hold about you. If we have not entered into a contract with you, we may process your personal data for these purposes where it is in our legitimate interest to do so for customer services;

send you certain communications (including by e-mail or post) about our goods and services, such as service announcements and administrative messages (e.g., implementing changes to our terms and conditions and keeping you informed about our fees) ;
allow you to attend our events or participate in the contests and send you pictures of you that you have authorized us to take;
to carry out safety and quality controls;
conduct statistical analysis and market research; and

if you have given your consent or, if it is in our legitimate interests, for marketing and business development purposes, to contact you (including by email or post) with information about our products and services which you request or which we think may be of interest to you (including newsletters), but only if you have consented.

Establish internal professional reports, for the purposes of administering our activities, ensuring appropriate coverage of our business, guaranteeing the security of the company's facilities, for research and development purposes or to improve the efficiency of operations.

To comply with all procedures, laws and regulations that apply to us; this may include cases where we reasonably consider such compliance to be in our legitimate interests or in the interests of others, but also where we are legally obliged to do so.

To establish , exercise or defend our legal rights; this may include cases where we reasonably consider it to be in our legitimate interests or in the interests of others, but also where we are legally obliged to do so.

If you visit one of our sites (including a brewery), for the purposes of video surveillance and to ensure the safety of our staff and visitors, as well as our and their property.
If you contact us on social networks, to monitor your interactions with us and our online brand, where it is in our legitimate interests for market research and to plan future marketing campaigns.

If we use your photo or video recordings of an event, to amplify the event to a wider audience and for internal presentation purposes, where we have your consent.

If you are a user of our maintenance tracking application, the CM/Spin application, to identify your location when providing maintenance services on our draught beer equipment and if it is in our legitimate interest to manage customer service requirements.
If you are a journalist, when you contact us it is in our legitimate interests to invite you to write an article about our products and services; to invite you to events, to send you promotional material and for press releases.

Legal basis used to process your personal data

The legal bases used for the processing of personal data listed in this Privacy Policy are as follows:

our use of your personal data is necessary to carry out our obligations under any contract with you (for example, to fulfil any orders you place with us, to comply with the terms of use of our websites or software applications that you agree to by browsing our websites or downloading our software applications, or to comply with our contract to provide services to or receive services from you or your employer); or

our use of your personal data is required to comply with our legal obligations (e.g. providing information to the tax and customs authorities); or

if neither (a) nor (b) applies, the use of your personal data is necessary for our legitimate interests or those of others (for example, to ensure the security of our websites or mobile applications). Our legitimate interests are as follows:

operate and develop our business ;
operate our websites and mobile applications;
select competent and qualified suppliers ;
ensure a safe working environment for our teams and visitors;
marketing, market research and business development ;
provide goods and services to our customers, issue and receive payments, provide services to customers and know the customer to whom we provide services;
placing, monitoring and guaranteeing the execution of orders with our suppliers; and

for internal group administrative purposes, as described in section 5.1 below.

You will find in Appendix 1 of this policy a summary table of the legal bases that we use for each processing operation.

We may use special categories of data where you have provided your consent (which you may withdraw at any time after giving it, as described below).

In the future, any further use of other personal data may be subject to your consent (which you may withdraw at any time after giving it, as described below). If this is the case, the need to obtain your consent will be identified in this Privacy Policy.
If we use your consent to process your personal data in a certain way, but you subsequently change your mind, you may withdraw it by contacting us at contact.france@asahibeer.fr. However, if you withdraw your consent, this may affect your ability to provide services to us (for example, if those services require health checks that involve the use of your special categories of data) or our ability to provide services to you.

Some pages on our websites and mobile applications use cookies, which are small files placed on your Internet browser when you visit our websites, mobile applications or use our applications. We use cookies to provide you with a more tailored experience in the future by understanding and remembering your specific browsing preferences.
When we use cookies on our website, you can block them at any time. To do so, you can activate the relevant setting on your browser, which allows you to refuse all or part of the cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or part of our Website or use all of the features provided.
For detailed information about the cookies we use and the purposes for which they are used, please refer to the cookie policy found on each of our websites and mobile applications.

Disclosure of personal data

We may share your personal data with any of our group companies, including our parent company based in Japan, where it is in our legitimate interests, for internal administrative purposes (for example, for purposes of consistency in the delivery of our services to our customers, corporate strategy, compliance, audit and control, research and development, and quality assurance). We may also share your personal data with companies within our group when these companies provide products and services to us, such as our IT system.
We will share your personal data with the following categories of third parties:

our service providers and subcontractors, including but not limited to payment service providers, technical and support service providers, insurers, logistics service providers and cloud service providers;
your employer or recruitment agency;
salesman of which you are a customer;
government agencies (including customs officers) ;
health examination providers and health professionals (where applicable) ;
companies that assist us in our marketing, advertising and promotional activities; and
providers of analytics and search engine services that help us improve our websites and software applications.

Third parties with whom we share your personal data are not permitted (by law or contract) to use this data for any purpose other than to provide services to us. We will always ensure that third parties with

whom we share your personal data are subject to confidentiality and security obligations that comply with this Privacy Policy and applicable laws.

We will also disclose your personal data to third parties:

when it corresponds to our legitimate interests to carry out and develop our activities:

if we sell or buy companies or assets, we may disclose your personal data to the prospective future buyer or seller;
substantially all of Asahi's assets or a portion of the assets of its affiliates are acquired by a third party, in which case personal data held by Asahi will be among the transferred assets;

if we are under an obligation to disclose or share your personal data in order to comply with any legal obligation, any lawful request from law enforcement officials or agents, and where necessary to meet national security and law enforcement requirements or to prevent unlawful activity ;
to enforce our terms and conditions or any other agreement, or to respond to any claims, protect our rights or the rights of any third party, protect the safety of any person or prevent any unlawful activity; or
to protect the rights, property or safety of Asahi, our staff, customers or others. This may include exchanging personal data with other organizations for the purposes of fraud protection and credit risk reduction.

We may also disclose and use aggregated anonymised reports or statistics about users of our websites, applications or goods and services from your interactions with us and our brands on social networks for internal reporting purposes, to our group or other third parties, and for marketing and promotional purposes. None of these reports or aggregated anonymised statistics will allow our users to be personally identified.
Except as expressly detailed above, we will never share, sell or rent your personal data to any third party without informing you and, where necessary, obtaining your consent. If you have given us your consent for us to use your personal data in a certain way, but later change your mind, you can contact us and we will stop the processing.

Retention of personal data

We keep your personal data for the time necessary for the purposes for which they are processed. The length of time we retain personal data depends on the purposes for which it is collected and used, but also on the requirements of applicable laws, and the establishment, exercise or defence of our legal rights. More information on the retention periods applied by Asahi is provided in Appendix 1 of this Policy.

Your Rights

You have certain rights regarding your personal data. If you wish to obtain further information on this subject or wish to exercise any of these rights, you may contact us at any time by e-mail at contact.france@asahibeer.fr. You have the right to request that we :

provide you with access to any personal data we hold about you;
update any personal data which are out of date or incorrect;
delete any personal data we hold about you;
Limitations on how we process your personal data;
prevent the processing of your personal data for direct marketing purposes;
whether or not to provide your personal data to a third party service provider;
provide you or a third party with a copy of the personal data we hold about you; (h)take into account any valid objections you have to our use of your personal data; or

(g) take into account any instructions you may provide to us regarding the use of your personal data after your death (for example, retention, deletion and disclosure). You may change or revoke your instructions at any time.

We will consider all such requests and respond to you within a reasonable time (always within the time limits imposed by applicable law). Please note, however, that some personal data may not fall within the scope of these requests in certain cases.
If an exception applies, we will notify you by responding to your request. We may ask you to provide us with the information necessary to confirm your identity before responding to any request issued.

Marketing

We may collect and use your personal data for marketing communications by e-mail, software application, telephone and mail.
We may 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.
However, we will always seek your consent for direct marketing communications if we are required to do so by law and if we intend to disclose your personal data to any third party for such marketing communications.
If you no longer wish to receive marketing communications, you may contact us at any time by e-mail at contact.france@asahibeer.fr.

Transfers of personal data

Personal data may be used, stored or accessed by teams working for us outside the EEA, by other members of our group or by Third Party Sources. This may be for the purposes listed in section 1.2(e) above, to provide our services to you or your employer, to receive services from you or our Third Party Sources, to process transactions and to provide support services. Further details of the persons to whom your personal data may be disclosed are given in Section 5 above.
If we provide personal data about you to affiliates or Third Party Sources outside the EEA, we will take appropriate steps to ensure that the recipient properly protects your personal data in accordance with this Privacy Policy. These measures include, but are not limited to

in the case of US-based entities, the conclusion of standard contractual clauses approved by the European Commission, or verification that they have adhered to the EU/US data protection shield (for more information: https://www.privacyshield.gov/welcome) or
in the case of entities based in other countries outside the EEA (including Japan), the conclusion of the standard contractual clauses approved by the European Commission with them.

For more information on how we protect your personal data during transfers, you can contact us at any time at contact.france@asahibeer.fr.Veuillez. Please note that we do not transfer any personal data outside the EEA except as part of our use of the Google Analytics cookie which enables us to carry out audience measurement. In this case, some of your login data may be transferred to Google in the USA, which has joined the EU/US data protection shield.

Security

Asahi is committed to protecting personal data from loss, misuse, disclosure, alteration, unauthorized access, unavailability and destruction, and takes all reasonable precautions to protect the confidentiality of personal data, including taking appropriate organizational and technical measures. Organisational measures include controls on physical access to our premises, staff training and the storage of physical files in locked filing cabinets. Technical measures include the use of encryption techniques, passwords to access our systems and anti-virus software.

By providing us with your personal data, your personal data may be transferred via the Internet. Although we strive to protect the personal data you provide to us, the transmission of information via the Internet is not completely secure. As such, you acknowledge and agree that we cannot guarantee the security of your personal data transmitted on our websites and that such transmission is at your own risk. Once we receive your personal data, we use strict procedures and security features to prevent unauthorised access to your data.
If we have given you (or if you have chosen) a password that allows you to access your account online, you are required to keep that password confidential. We ask you never to disclose a password.

Third Party Websites

Our websites, mobile applications and social networking pages may from time to time contain links to websites operated by third parties, including partner networks and our group companies. Please note that this Privacy Policy applies only to personal data that we collect through our websites, applications and social network pages, or that we receive from Third Party Sources. We are not responsible for personal data collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read them carefully before providing your personal data on such websites. We do not assume or accept any responsibility for the content of these third party websites, their terms and conditions or other policies.

Changes to our Privacy Policy

We may update our privacy policy from time to time. Any future changes to our privacy policy will be posted on this page and, where appropriate, will be notified to you by post or email. Please check this page regularly for any updates or changes to our privacy policy. By continuing to use the Services and our websites, or offering or providing services to us, you confirm that you have read and understand the latest version of our Privacy Policy.

Other questions or complaints

If you have any questions or complaints about our collection, use or storage of your personal data, or if you wish to exercise any of your rights regarding your personal data, please contact us atcontact.france@asahibeer.fr . We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data.
You may also submit a complaint to the data protection authority in the EU country where we are established or where we process personal data relating to our provision of goods or services to you in the European Union. If you do not know which data protection authority to contact, please write to contact.france@asahibeer.fr and we will inform you. You can also seek redress through the local courts if you believe your rights have been violated.

This Privacy Policy has been amended following the coming into force of the Data Protection Regulation to take into account new legal requirements.

Annex 1: Table of legal bases and retention periods used

Main purpose of the treatment	Sub-purpose of processing		Legal basis	Shelf life
Visit our websites or, if you are a consumer, use one of our software applications.	allow you to access or use our website or the application (including ensuring that you are of legal drinking age)		Our legitimate interest and your consent	Immediate deletion
	provide technical assistance		Our legitimate interest	3 years after contact with you	last
	provide you with the information and services you request from us		Your Consent	3 years after contact with you	last
	ensure the security of our services, websites and application		Our legitimate interest	3 years after contact with you	last
	store information about your preferences, and allow us to customize our websites and the application according to your interests		Your consent (cookies)	13 months after the deposit of the cookie
	recognize you when return to our websites	you	Your consent (cookies)	13 months after the deposit of the cookie
	if you are a user of the Application, to recognize your location to enable the Application to work by showing you nearby bars, to monitor the use of the Application and the consumption of beer, to conduct market research and to understand your preferences and experience in places selling our products (e.g., a hotel, bar or restaurant); and		Your Consent	3 years after your last login to your account
	allow you to participate in our contests and promotions		Your Consent	3 years after the end of the business relationship (customers) / 3 years after the last contact with you (prospects)
	process the orders you place for our goods and services		Execution of the contract concluded with you	3 years after the end of the business relationship / duration of the applicable legal obligation
	improve and maintain our websites and the application and prepare reports or compile statistics in order to improve our goods and services. These details will be anonymised to the extent reasonable and you will not be identifiable from the data collected.		Our legitimate interest	3 years after contact with you	last

Receiving goods and services from you	enable us to receive and manage your services (including supplier audits, payment and expense reports and financial audits)	Execution of the contract concluded with you	3 years after the end of the business relationship
	safety records and related management	Our legitimate interest	3 years after the end of the business relationship
	assess your ability to work	Our legitimate interest	3 years after the end of the business relationship
Providing goods and services	provide relevant goods or services to you or your employer (including confirming and processing orders, managing your account with us, customer loans, for tax and export purposes, billing and debt collection, and bottle collection [if applicable]); and	Execution of the contract concluded with you	3 years after the end of the business relationship
	manage your requests or problems with our products and services, including any questions about how we collect, store and use your personal data, or any request for you to obtain a copy of the data we hold about you. If we have not entered into a contract with you, we may process your personal data for these purposes where it is in our legitimate interests to do so for customer services.	Performance of the contract concluded with you or our legitimate interest	3 years after the end of the business relationship (customers) / 3 years after the last contact with you (prospects)
	send you certain communications (including by e-mail or post) about our goods and services, such as service announcements and administrative messages (e.g., implementing changes to our terms and conditions and keeping you informed about our fees)	Performance of the contract concluded with you or our legitimate interest	3 years after the end of the business relationship (customers) / 3 years after the last contact with you (prospects)
	allow you to attend our events or participate in contests and send you photos of you that you have authorized us to take	Your Consent	3 years after the end of the commercial relationship (customers) / 3 years after the last contact with you (prospects)
	carry out safety and quality controls	Our legitimate interest	3 years after the end of the business relationship (customers) / 3 years after the last contact with you (prospects)
	conduct statistical analysis and market research	Our legitimate interest	3 years after the end of the business relationship (customers) / 3 years after the last contact with you (prospects)

	if you have given your consent or, if it is in our legitimate interests, for marketing and business development purposes, to contact you (including by e- mail or post) with information about our products and services which you request or which we think may be of interest to you (including newsletters), but only if you have consented to this	Your Consent	3 years after the end of the business relationship (customers) / 3 years after the last contact with you (prospects)
To establish internal professional reports, for the purposes of administering our activities, ensuring appropriate coverage of our business, guaranteeing the security of the company's facilities, for research and development purposes or to improve the efficiency of operations.	/	Our legitimate interest	Statutory limitation period or 3 years after the end of the business relationship
Comply with all procedures, laws and regulations that apply to us; this may include cases where we reasonably consider that compliance is in our legitimate interests or those of others, but also where we are legally required to do so.	/	Compliance with our legal obligations or legitimate interest	Duration of the legal obligation or 3 years after the end of the business relationship
Establish, exercise or defend our legal rights; this may include cases where we reasonably consider it to be in our legitimate interests or those of others, but also where we are legally obliged to do so.	/	Our legitimate interest	Statutory limitation period or 3 years after the end of the business relationship
If you visit one of our sites (including a brewery), for the purposes of video surveillance and to ensure the safety of our staff and visitors, as well as our property and their property	/	Our legitimate interest	1 month
If you contact us on social networks, monitor your interactions with us and our online brand, where it is in our legitimate interests for market research and to plan future marketing campaigns.	/	Our legitimate interest	3 years after last contact with you

If we use your photo or video footage of an event, to extend the reach of the event to a wider audience and for internal presentation

purposes, where we have your consent

Your Consent

Duration indicated in the image right authorization form

If you are a user of our maintenance tracking application, the CM/Spin application, to identify your location when providing maintenance services on our draught beer equipment and if it is in our legitimate interest to manage customer service

requirements.

Performance of the contract concluded with you or our legitimate interest

Statutory limitation period or 3 years after the end of the business relationship

If you are a journalist, when you contact us it is in our legitimate interests to invite you to write an article about our products and services; to invite you to events, to send you promotional

material and for press releases.

Our legitimate interest

Duration of the journalistic profession