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Heineken Hot Lap — Privacy Notice

This Privacy Notice explains how United Breweries Limited ("UBL", "we", "us" or "our") collects, uses, stores and otherwise processes your personal data when you register for and participate in the Heineken Hot Lap game ("Game") through the Heineken Hot Lap microsite ("Microsite").

Please read this Privacy Notice carefully before registering for the Game.

1. Who is responsible for your personal data?

UBL is responsible for the processing of your personal data in connection with the Game.

We may appoint authorised service providers and agencies to operate the Microsite, Game, communications, customer support, technology, analytics and other campaign-related activities on our behalf. These service providers will process your personal data only for authorised campaign purposes and in accordance with our instructions and applicable law.

2. What personal data do we collect?

Depending on how you use the Microsite and Game, we may collect your name, age or date of birth, gender, mobile number, email address and city for the purposes of registering you for the Game, administering your Game account, verifying your eligibility, administering your participation and, where applicable, conducting aggregated campaign analysis.

We may collect your Game ID, score, participation details, Game activity and related timestamps to operate and administer the Game, maintain your score and administer your participation in the Game.

If you choose to use the optional product-scanning booster feature, we may collect information relating to your product scan to validate your participation in and administer the booster feature.

We may also collect device, browser, IP address and other technical or log information generated through your use of the Microsite and Game for purposes including operating and securing the Microsite and Game, troubleshooting technical issues, preventing misuse or fraudulent activity and improving the Microsite and Game.

We may collect communication preferences and records of consent or withdrawal of consent to administer your communication preferences and maintain records of your choices.

We will collect only the personal data reasonably required for the purposes described in this Privacy Notice.

3. How do we collect your personal data?

We collect personal data:

• when you register on the Microsite;
• when you participate in or interact with the Game;
• when you use the optional product-scanning booster feature;
• when you contact us or our authorised campaign support team; and
• automatically through technical information generated when you use the Microsite, such as device, browser, IP address and log information.

4. Why do we use your personal data?

We may process your personal data to register you for the Game and create and administer your Game account; verify your eligibility to participate; operate and administer the Game; maintain and administer your Game score and activity; provide the optional product-scanning booster feature; send necessary Game-related communications; respond to your queries and provide customer support; maintain the security and integrity of the Microsite and Game and prevent fraud, misuse or abuse; conduct aggregated and/or anonymised analysis to understand campaign performance and improve the Game and campaign experience; and comply with applicable legal and regulatory requirements.

We will not use your personal data for purposes that are incompatible with the purposes described in this Privacy Notice without providing the required notice and obtaining consent where required by applicable law.

5. Game-related communications

As part of your participation in the Game, we may send you communications that are necessary to administer your participation, such as registration or authentication messages, Game-related notifications, information relating to your score or participation, responses to your queries and other service communications relating to the Game.

These communications are not intended to be marketing communications.

Where these communications are necessary to provide or administer the Game, you may not be able to opt out of receiving them while participating in the Game.

Where a communication is intended to be promotional or marketing in nature, we will not treat your participation in the Game as consent to receive such marketing communications and will obtain any consent required under applicable law.

6. Optional product-scanning booster

The Game may provide an optional feature through which you can use your device camera to scan an eligible Heineken product for the purpose of receiving a Game score booster.

Use of this feature is optional and is not required to participate in the Game.

When you choose to use the feature, the Microsite may request access to your device camera. The camera will be activated only when you choose to use the scanning feature.

The booster feature is subject to the Game rules, including a limit of one eligible product scan per user in any 24-hour period.

7. Who may we share your personal data with?

We may share your personal data, where necessary for the purposes described in this Privacy Notice, with authorised service providers and agencies supporting the campaign, including providers involved in Microsite and Game development and hosting, campaign administration, customer support and CRM operations, communications and messaging services, technical support and security, analytics and campaign reporting, and other services necessary to operate the Game.

Such parties will receive access only to the personal data reasonably required for the services they provide and will be subject to appropriate contractual and confidentiality obligations.

We may also disclose personal data where required to do so by applicable law, regulation, legal process or a lawful request from a competent authority.

8. WhatsApp communications

Where necessary to administer your participation in the Game, we may use WhatsApp and authorised messaging service providers to communicate with you using the mobile number provided during registration.

The relevant WhatsApp communication may appear under the name "Heineken Hot Lap".

These communications are intended to be limited to Game-related/service communications and are not intended to constitute marketing communications.

Your mobile number and relevant communication information may be processed by the service providers involved in delivering these messages for this purpose.

9. International processing

Some of our authorised service providers or technology providers may process or store personal data outside India.

Where this occurs, UBL will take steps required under applicable law in relation to such processing, including any applicable requirements concerning transfer of personal data outside India.

10. How do we protect your personal data?

We maintain reasonable technical and organisational safeguards designed to protect personal data against unauthorised access, loss, misuse, alteration, disclosure or destruction.

Access to personal data will be limited to persons and service providers who require access for authorised campaign purposes.

11. How long do we retain your personal data?

We will retain your personal data only for as long as reasonably necessary for the purposes described in this Privacy Notice, including to administer the Game, resolve disputes or queries, maintain appropriate records, prevent misuse and comply with applicable legal and regulatory requirements.

Different categories of personal data may be retained for different periods depending on the purpose for which they were collected.

Where personal data is no longer required for the purposes for which it was collected, or where retention is no longer required or permitted under applicable law, it will be deleted or otherwise appropriately disposed of.

12. Your rights

Subject to applicable law, you may have rights in relation to your personal data, including rights to:

• request information about the personal data we process about you;
• request correction or updating of inaccurate or incomplete personal data;
• request deletion of personal data where applicable;
• withdraw consent where processing is based on consent;
• raise a grievance regarding the processing of your personal data; and
• exercise any other rights available to you under applicable law.

To exercise your rights or raise a privacy-related concern, please contact us using the details provided below.

13. Grievances and complaints

If you have any questions, concerns or complaints regarding the processing of your personal data, you may contact our privacy/grievance contact at:

We will address your grievance in accordance with applicable law.

14. Changes to this Privacy Notice

We may update this Privacy Notice from time to time to reflect changes to the Game, our processing activities, applicable law or our privacy practices.

The updated Privacy Notice will be made available on the Microsite and will indicate its effective date.