AB InBev ABI_RMCC learning platform privacy policy

Privacy and Cookie Policy for abi rmcc training website

[version 1 updated on 03.11.2020]

This internet website, which is owned and operated by [ANHEUSER-BUSCH INBEV SA/NV, a company organized and existing under the laws of Belgium, having its registered office at Grote Markt 1, 1000 Brussels, Belgium, registered with the Register of Legal Entities under company number VAT 0417.497.106 RPM Brussels] and its Affiliates (“ABI”, “we”, “our” or “us”) and operated by a BRIGHTWAVE ENTERPRISES LTD on our behalf and instructions. E-mail: jenny.coombs@capita.co.uk and Phone: 01273 827676.

To ensure that you feel safe and happy visiting and using our Website, the following information gives you a comprehensive guide as to what we do with your personal data and more specifically how we collect, use and pass on your personal data when you use this Website.

This Privacy and Cookie Policy also describes our use of cookies, how your personal data are secured and how you can contact us about our privacy practices, including:

1.         Data collection: What information do we collect?

2.         For which purposes do we use your information and on which legal bases?

3.         How do we share your information?

4.         What are your rights?

5.         Who can you contact in case you have questions or requests? The data protection contact point

6.         Links to Third-Party Sites

7.         Do-Not-Track Signals and Similar Mechanisms.

8.         Cookies and similar technologies

8.1.      What are cookies and similar tracking technologies?

8.2.      For what purposes do we use cookies?

8.3.      What types of cookies do we use?

8.2.      How can you control, delete or withdraw your consent to the use of cookies ?

9.         Targeting technologies

10.       International Transfers

11.       Security

12.       Children’s Privacy

13.       Changes to this Privacy and Cookie Policy

Please read this Privacy and Cookie Policy before using or submitting any personal data on this Website.

By accessing and using this Website, you confirm that you have read and that you understand the way we collect, process, use and disclose your personal data as described herein.

Please note that before using or submitting personal data on certain sections of this Website, you may be asked to confirm electronically your understanding and acceptance of this Privacy and Cookie Policy by ticking specific boxes and/or clicking on certain buttons. Your affirmative action in ticking that box and/or clicking on that button and your use of this Website means that you understand and agree to the collection, processing, use and transfer of your personal data as described in this Privacy and Cookie Policy.

Our records of your acceptance of this Privacy and Cookie Policy, the date thereof, and of all future amendments to this Policy, shall be regarded as conclusive and written evidence of your consent, whenever consent is the legal basis applicable.

Data collection: What information do we collect?

Depending on the purpose of the processing, we need to process the following categories of personal data about you:

  • your name and email address, which you are asked to provide when you register a user account on this Website and/or are directly provided by your employer;
  • your employer’s name and location, which you are asked to provide when you register a user account on this Website and/or are directly provided by your employer;
  • connection and browsing data (if you interact with the Website from your laptop or mobile phone, and which content of the Website you have accessed, for example) that we collect by using cookies and similar tracking technologies as described under Section 8 “COOKIES AND SIMILAR TECHNOLOGIES” below;
  • commercial information (for example, if you have participated to a survey and the answers you have provided thereto).

For which purposes do we use your information and on which legal bases?

The Website main purpose is to provide you with training and educational content regarding ABI standard practices and requirements for marketing activities. In addition, the Website may provide other services from time to time (all services available on the Website are referred to as “the Services”).

Depending on the Services that you wish to use on the Website, we will process your personal data for the following purposes, as justified on the following legal bases:

PURPOSELEGAL BASIS
To manage your registration on the Website, to grant you access to the Services, to understand how you use and interact with the Services, which includes keeping records of the trainings you have accessed and completed in the Website and to contact you in the context of the delivery of the Services.Your personal data will be processed based on ABI’s legitimate interest to ensure that all professionals involved in the performance of marketing services are aware and duly trained of the policies implemented by ABI for the marketing campaigns related to its brands.

We will only process your personal data for specified, explicit and legitimate purposes and we will not process your personal data further in a way that is incompatible with those purposes. Where required under applicable law, we will also collect your express consent to any of the above-mentioned activities. Whenever consent is applicable, you have the right to withdraw any given consent at any time.   

How do we share your information?

For the purposes for which we collect your personal data and subject to the appropriate legal basis described under Section 2 above, we may disclose your personal data to the following categories of recipients:

a)         Authorised staff members of ABI who access your personal data on a need-to-know basis;

b)         Affiliates and subsidiary companies of ABI, primarily for business and operational purposes;

c)         Service providers: companies that provide Services on behalf of ABI and under our instructions, that provide services to us, for the purposes of providing the Website or our Services;

d)         Other parties when required by law: ABI may share your personal data with other third parties:

–           to comply with the law, regulatory requests, court orders, subpoena, or legal processes;

–           to verify or enforce compliance with ABI’s policies and agreements; and

–           to protect the rights, property or safety of ABI, its customers, visitors to this Website and/or the public.

e)         Please be aware that service providers who may offer products and/or services to you through their services or via their own channels may separately collect personal data from you. In such case, ABI is not responsible for the collection of this data. These third parties are solely responsible for the control of such personal data and the processing of your data will be subject to their Privacy Policy.

The above recipients of your personal data may be located within or outside the EEA, including in countries not recognized by the European Commission as offering an adequate level of protection of personal data. Please refer to Section 10 below for information regarding such transfers and the appropriate safeguards implemented by ABI.

What are your rights?

Under the conditions set forth under applicable data protection laws, you have the right to access and rectify your personal data, as well as the right to object at any time to the processing of your personal data for direct marketing purposes, including profiling related to such direct marketing, and, in certain cases, to object to the processing based on grounds relating to your particular situation. In addition, you have the right to request the restriction of the processing and the erasure of your personal data (right to be forgotten) as well as the right to data portability. When the processing of personal data is based on you consent, you have the right to withdraw your consent at any time.

You can exercise these rights by sending a written request to our data protection contact (see Section 5 “WHO CAN YOU CONTACT IN CASE YOU HAVE QUESTIONS OR REQUESTS?”).

You also have the right to lodge a complaint with your competent supervisory authority.

If you require further information in relation to your privacy rights or would like to exercise any of these rights, please also contact our data protection officer (see Section 5 “WHO CAN YOU CONTACT IN CASE YOU HAVE QUESTIONS OR REQUESTS?”).

Who can you contact in case you have questions or requests? The data protection contact point

ABI has in place a data protection contact point available for you to submit your questions or requests relating to the processing of your personal data. You can access this data protection contact point in our global “contact us” website (https://contactus.ab-inbev.com).

When you exercise these rights, ABI may collect your name, e-mail address and your request details. Please be aware that ABI only requires your e-mail address and request in order to process your request. Other details are optional for you to share with us. Your personal details will be saved only so that we can respond to your request, and will subsequently be deleted, unless there are legal requirements stipulating the retention of these data.

Please contact our data protection contact point or our data protection officer indicated above if you wish to exercise your rights as data subject in the terms described in Section 4.

Links to Third-Party Sites

We are not responsible for the security or privacy of any information collected by other websites, applications, or other services or by your mobile operating system operator, wireless carrier, or other similar providers. You should exercise caution and review the privacy statements applicable to the third-party websites, applications and services you use.

Do-Not-Track Signals and Similar Mechanisms. 

Some web browsers may transmit “do-not-track” signals to websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, the Website and Services currently do not take action in response to these signals. If and when a final standard is established and accepted, we will reassess how to respond to these signals.

Cookies and similar technologies

8.1.          What are cookies and similar tracking technologies?

Cookies are small text files that are placed on your device by websites that you visit.

They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of websites or applications. Cookies and other tracking technologies can be used to identify and track users as they navigate different pages on the Website and identify users returning the Website.

8.2.          For what purposes do we use cookies?

Two types of cookies may be used, “session cookies” (automatically deleted at the end of your browning session) and “persistent cookies” (will remain valid until its set expiry date, unless deleted by the user before the expiry date).

This Website uses cookies for the following purposes:

  • to perform essential functions, such as the authentication of the user;
  • to make this Website perform easier to use; and
  • to compile anonymous, aggregated statistics that allow us to understand how users use the Website and to help us improve the structure and content of the Website.

By clicking the [“I Accept” button] and/or selecting your cookie preferences on the ABI Cookie Consent and Management Banner, you are agreeing to our use of cookies and similar technologies in line with your current cookie setting/preferences and in accordance with this Privacy and Cookie Policy. You will always be able to withdraw your consent and change your choice/preferences by amending your settings/updating your preferences in our ABI Cookie Consent and Management Banner in the future. If you disable cookies that we use, this may impact your user experience while on this Website.

8.3.          What types of cookies do we use?

This Website uses the following cookies:

Type of CookieNamePurposeMore information
TemporaryJSESSIONIDUsed to maintain an anonymous user session by the server.Expires at the end of the session
TemporaryProxy-Auth-1055Used to authenticate client requests and maintain session informationExpires at the end of the session
TemporaryProxy-Auth-1096Used to authenticate client requests and maintain session informationExpires at the end of the session
TemporaryProxy-Auth-1014Used to authenticate client requests and maintain session informationExpires at the end of the session
Temporary_RequestVerificationTokenUsed to stop unauthorised posting of content to a website, known as Cross-Site Request Forgery. It holds no information about the user and is destroyed on closing the browser.Expires at the end of the session
TemporaryASP.NET_SessionIdUsed to maintain an anonymised user session by the server.Expires at the end of the session

 

How can you control, delete or withdraw your consent to the use of cookies?

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org.  

If you wish to withdraw your consent to our use of cookies on this Website, or if you wish to delete or control the placing of cookies on your device, you can change your browser settings to block cookies or to alert you when cookies are being sent to your device. There are a number of ways to manage cookies. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings at:

Please note: if you choose to fully disable the use of cookies on your browser, this Website might not display or function as designed on your device. You can also always decide to change your cookie preferences on our ABI Cookie Consent and Management Banner.

For any further information regarding your rights, please refer to Section 4 “WHAT ARE YOUR RIGHTS?” and 5 “WHO CAN YOU CONTACT IN CASE YOU HAVE QUESTIONS OR REQUESTS?” above.

International Transfers

The Website is hosted by servers located in the United Kingdom. If you are attempting to access this Website from a physical location within the United States, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from European Union laws, please be advised that your use of this Website is governed by the General Data Protection Regulation (European law) and national law (Belgian law) and these Terms and Conditions. To the extent you provide personal data through the Website, you are transferring your data to Belgium.

In connection with any transfer of your personal data to outside the European Economic Area (= member states of the European Union + Iceland, Norway, and Liechtenstein, “EEA”) in countries that are not recognized by the European Commission as offering an adequate level of data protection (no ‘adequacy decision’), we implement appropriate safeguards to ensure an adequate level of protection of your personal data. These safeguards can for instance consist in agreeing with recipients on standard data protection clauses in the form of entering into template model clauses such as the Standard Contractual Clauses for the transfer of personal data to third parties adopted by the European Commission guaranteeing such adequate level of protection. You may obtain a copy of such safeguards (Standard Contractual Clauses) by contacting us at data protection officer, First Privacy GmbH, at: e-mail: abi-team@firstprivacy.com ; phone: +49 421 69663282.

Security

We ensure that appropriate technical and organisational security measures are taken against unlawful or unauthorised access or use of your personal data, as well as against accidental loss or damage to the integrity of your personal data.

We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or Services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities. 

Your personal data will only be processed by a third-party data processor if that data processor agrees to comply with those technical and organisational data security measures.

Maintaining data security means guaranteeing the confidentiality, integrity and availability of your personal data:

(a)        Confidentiality: we will protect your personal data from disclosure to third parties.

(b)        Integrity: we will protect your personal data from being modified by unauthorised third parties.

(c)        Availability: we will ensure that authorized parties are able to access your personal data when needed.

Children’s Privacy

Please note that our Website is only available for non-professional consumers. Do only share the content of our Website with those who are of legal drinking age. Our Website and Services are not intended for individuals under the legal drinking age. If we learn that an individual under the legal drinking age has provided us with personal information, we will delete it.

Changes to this Privacy and Cookie Policy

Except to the extent limited by applicable law, ABI may decide at any time − at its discretion − to change, modify, and/or add all or parts of this Privacy and Cookie Policy in the future. Any change to this Privacy and Cookie Policy will be posted on this page and, notified to you by e-mail (where appropriate or required by law and to the extent that we have your e-mail address). We will indicate at the top of this Privacy and Cookie Policy the date on which the Policy was last modified. Where required by law, we may also ask you to expressly confirm your consent to the modified Privacy and Cookie Policy.