The Carlsberg group understands that the security of your personal data is extremely important and it is committed to respecting your privacy and safeguarding your personal data.
- What personal data we collect
- What we do with your personal data
- Your use of chat rooms, message boards or other interactive forums
- How we protect your personal data
- Your rights and contacting us
- Updates to this policy
1 What personal data we collect
We will collect and process some or all of the following personal data about you:
- Information about you your name, address, email address, phone number, social media handle, gender, date of birth or photograph, or details of your employer and your position
- Your transaction details and purchase history details of purchases and other transactions you have made, including through our websites or through other channels, including the delivery address and details of the products purchased
- Payment details payment details used to purchase our products and services, such as credit/debit card number and expiry date
- Information we collect about your participation in our promotions and competitions or attendance at our events information provided in your application forms, recordings you or we have made, details of your guests in connection with any promotions and competitions you have entered or won, or other information related to your attendance at events, including any dietary and access assistance requirements you may have
- Information about your interests details of any hobbies or activities you undertake], [details of your personal interests] or other information
- Marketing preference information details of your marketing and communication preferences and information we collect to help us determine what products and services may be of interest to you
- Information about your use of our social media pages or other interactive forums including any comments, photos, videos or other information that you post online
- Survey information your responses to market surveys that we conduct
- Our correspondence with you including any feedback, complaints and comments from you via telephone, email or social media, or records of any online, paper or in-person correspondence and interactions between us. If you have communicated with us by phone, we will collect details of the phone number used to call us, and any information collected via a call recording
- Credit and anti-fraud information information relating to your financial situation, your creditworthiness or any criminal or fraudulent activities provided to us by you or third parties
- Technical information including the Internet protocol (IP) address used to connect your computer to the Internet, or your login information, browser type and version, time zone setting, browser plug in types and versions, operating system and platform
- Information about your visit to our websites including the full Uniform Resource Locators (URL) clickstream to, through and from our websites (including date and time), products you viewed or searched for, pages you accessed, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page
DESCRIBE ANY OTHER TYPES OF INFORMATION COLLECTED
Sources of personal data
We collect much of the personal data that we hold about you directly from you or your interactions with us, our websites or social media sites. We may also receive your personal data from other sources, including business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies, anti-fraud databases and other third party databases, including sanctions lists, and business information and research tools.
Sensitive personal data
Under data protection law, certain categories of personal data are considered particularly sensitive and, therefore, as needing additional protection. These categories include information about health, racial or ethnic origin, political opinions, religious beliefs, trade union membership or your sexual orientation, and genetic and biometric data. Information concerning criminal convictions and offences is also viewed as sensitive under European data protection law.
In limited circumstances, we will collect and handle such sensitive personal data, for example, when we handle requests for special medical or access assistance or your specific dietary requirements in connection with your attendance at an event, which may indicate your religious beliefs, e.g. halal or kosher meal selections, or where we undertake certain background checks on you, which may disclose information about previous criminal convictions. We handle this sensitive personal data in compliance with applicable data protection laws, including as described further in the “What we do with your personal data” section below.
2 What we do with your personal data
Under European data protection laws (European Data Protection Laws) we must establish and inform you of a legal basis or “ground” for our use of your personal data. For each use mentioned below we note the purpose for which we use and disclose it, and the ground we rely on as the basis for our use. An explanation of each of the grounds can be found [here].
Depending on how you interact with Somersby, we will use your personal data for the following purposes:
- To provide and manage products and services you have requested: To carry out our obligations arising from any contracts entered into between you and us, including to arrange delivery, to action or cancel orders, to provide you with the information, products and services that you request from us, and to notify you about changes to our products and services
Legal bases: contract performance, legitimate interests (to enable us to perform our obligations and provide products and services to you or to notify you about changes to our products and services)
- To communicate effectively with you To respond to your questions, comments, complaints or other communications, including any queries relating to our products
Legal bases: legitimate interests (to allow us to correspond with you and provide products and services to you), legal claims
- To monitor activities and record our correspondence with you To monitor our communications with you, including to ensure service quality, compliance with procedures and for training purposes
Legal bases: legitimate interests (to ensure the quality of our products and services)
- To provide you with marketing materials To provide you with information by post, email, phone, SMS, or online or social media advertisement about products and services that we offer where such products or services are similar to those you have already purchased or enquired about, or where you have consented to being contacted for those purposes. We may also use your information for marketing selected business partners’ products and services. Where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing sent to you or you may opt out at any time by contacting us using the details set outin the “Contact” section below
Legal bases: consent, legitimate interests (to keep you updated with news in relation to our products and services)
- To understand our customers, and to develop and tailor our products and services We may analyse the personal data that we hold in order to measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you. We may report aggregate information to our advertisers, and make suggestions and recommendations to you, our customers and users of our websites about products or services that may interest you or them
Legal bases: legitimate interests (to ensure the quality of our products and services, allow us to improve our products and services, and provide you with the content and services on our websites)
- To run our promotions and competitions Where you are participating in promotions and competitions, to run such promotions and competitions, including to notify you if you have won. If you win a prize, in accordance with local law, we may make your personal data and your guests’ personal data available on our websites and social media pages and in press releases. We may also make these details available to third parties who may need this information for prize fulfilment purposes
Legal bases: legal obligations, contract performance, legitimate interests (in order to successfully run our promotions and events)
- To run our events If you attend an event organised or otherwise supported by us, we may use your personal data, including specific dietary requirements, health information and access assistance, in connection with the running of the event
Legal bases: legitimate interests (to allow us to run our events, and to cater for and accommodate your specific preferences and requirements during our events), explicit consent (if required)
- In relation to fraud prevention We and other organisations may access and use certain information to prevent fraud as may be required by applicable law and regulation, and best practice, at any given time. If false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies and other organisations, and may be recorded by us or them
Legal bases: legal obligations, legitimate interests (to ensure that you fall within our acceptable risk profile and to assist with the prevention of crime and fraud), substantial public interest
- To conduct certain checks on you, such as KYC and credit checks If you are a customer or prospective customer, we may use your personal data to conduct certain checks in relation to you (and or your business). In connection with this purpose, we may disclose your details to the relevant authorities including credit reference agencies, government agencies and fraud prevention agencies. Law enforcement agencies may access and use this information. We, and other organisations that access and use information recorded by such agencies, may do so from countries other than the country in which you are based
Legal bases: legal obligation, legal claims, substantial public interests, legitimate interests (to assist with the prevention of crime and fraud)
- To improve and administer our websites, and to ensure that content is relevant To ensure that only adults of legal drinking age view and interact with our websites; to improve our websites and ensure that content is presented in the most effective manner for you and your computer; to administer our websites and for internal operations, including troubleshooting, data analysis (including traffic data analysis), testing, and research, statistical and survey purposes; to allow you to participate in / register for interactive features of our service; as part of our efforts to keep our websites safe and secure; to ensure that content from our websites is presented in the most effective manner for you and for your device, which may include passing your data to business partners, service providers, and analytics and search engine providers
Legal bases: legitimate interests (to allow us to administer our websites and to provide you with the content and services on our websites), legal obligation
Legal bases: legitimate interests (in order to allow us to change our business), legal obligation
- To comply with legal and regulatory obligations We may process your personal data to comply with our legal and regulatory requirements, which may include disclosing your personal data to third parties, including insurers, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so
Legal bases: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities)
If you have any questions about the legal bases we rely on, please contact us using the details set outin the “Contact” section below.
Disclosure of your information
In addition to the third parties mentioned above, we may also disclose your personal data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who may use it in connection with any of the purposes set out above. We will also share your personal data with third party service providers (such as providers of marketing, IT or administrative services) who may process it on our behalf for any of the purposes set out above.
We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in a particular location). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
3 How we use "cookies"?
4 Your use of chat rooms, message boards or other interactive forums
5 How we protect your personal data
Where is your personal data stored?
The data that we collect from you may be transferred to, and stored at, a destination outside Hong Kong. It may also be processed by staff operating outside Hong Kong who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details or the provision of support services.
How long is your personal data stored for?
The personal data that we hold about you will not be kept for longer than is permitted by law and will only be kept for as long as necessary to provide you with any requested products, services or information, or for any other purpose set out under the heading “What do we do with the information” above.
For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data.
What do we do to safeguard personal data?
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology.
Where we have given you (or where you have chosen) a password that enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our websites - any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
What about links to other sites?
Our websites and social media fan pages may, from time to time, contain links to and from the websites of our partner networks, affiliates and other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
6 Your rights and contacting us
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you or collect your consent (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data or clicking unsubscribe at the bottom of the emails we send thko you for marketing purposes. You can also exercise the right at any time by contacting us at email@example.com.
We will use reasonable endeavours to ensure that your personal data is accurate. In order to assist us with this, you should notify us of any changes to the personal data that you have provided to us by contacting us using the details set out in the “Contact” section below.
If you are based in the EEA during your interactions with us, under certain conditions, you may have the right to require us to:
- provide you with further details on how we use and process your personal data;
- provide you with a copy of the personal data that we hold about you;
- rectify inaccuracies in the personal data and complete any incomplete personal data that we process about you;
- delete personal data we no longer have grounds to process; and
- restrict how we process your personal data whilst we consider an inquiry you have raised.
In addition, under certain conditions, you have the right to:
- where processing is based on consent, withdraw the consent;
- ask us to transmit the personal data you have provided to us and that we still hold about you to a third party electronically;
- object to any processing of personal data that we process on the “legitimate interests” or “public interests” grounds, unless our reasons for the underlying processing outweigh your interests, rights and freedoms; and
- object to direct marketing (including any profiling for such purposes) at any time.
These rights are subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege), and may not all be available in the country in which you are based.
If you have the right to do so, you can exercise these rights by contacting us using the details set out in the “Contact” section below.
If you are not satisfied with our use of your personal information or our response to any exercise of these rights you have the right to complain to the Privacy Commissioner for Personal Data, Hong Kong.
Corporate Affairs Director, Asia
21F, Delta House, 3 On Yiu Street, Siu Lek Yuen, Shatin, Hong Kong
7 Updates to this policy