Last Updated: May 1,2023
Heineken USA Incorporated (“Heineken,” We,” “Us,” or “Our”) provides the following details regarding the Personal Information that We collect and use about you in the context of your current, former, or potential role as Our employees, independent contractors, consultants, and job applicants. This Privacy Policy also applies to your emergency contacts and benefits beneficiaries.
Categories of Personal Information
- Identifiers, such as name, contact information (address, phone numbers, emails, etc.), photograph, Employee number, online identifiers, IP address, and Social Security numbers and other government-issued ID numbers;
- Personal information, as defined in the state employee records laws, such as name, contact information, date of birth, education, languages spoken, employment, employment history, financial information and medical and medical insurance information;
- Characteristics of protected classifications under California, other applicable state laws or federal law, such as sex, age, race, religion, national origin, disability, medical conditions and information, citizenship, immigration status and marital status;
- Internet or network activity information, such as browsing history and interactions with Our and other websites and systems, electronic content produced using company systems, including mobile devices and incident response data;
- Audio, electronic, visual, and similar information, such as photographs or audio or video recordings created in connection with Our business activities;
- Professional or employment-related information, such as work history, prior employer, information relating to references, details of qualifications, skills and experience, human resources data, compensation and payroll (salary, bonus, benefits, compensation type, salary level, equity plans and other awards, pay frequency, effective date of compensation, salary reviews, banking details, working time records, expenses), office location, status and type (full-time/part-time), terms of employment, hire/re-hire dates, termination date(s) and reason, length of service, promotions and disciplinary records, positions, title, corporate status, management category, data necessary for benefits and related administration services, emergency contact information, and details of any shares of common stock or directorships;
- Education information subject to the federal Family Educational Rights and Privacy Act; and
- Sensitive data, such as information revealing physical or mental health, data related to disabilities and absence due to illness or pregnancy; data relating to criminal behavior, criminal records, background checks or processing regarding criminal or unlawful behavior; religious or philosophical beliefs; data revealing sexual orientation or gender identity; and racial or ethnic data.
How We Collect Your Personal Information
We collect personal information about employees, workers, contactors, and job applicants through the application and recruitment process, directly from candidates, employment agencies, and screening and testing services or other background-check providers. We may collect additional information from third parties including former employers, credit reference agencies, or other sources that supply employment verification services.
We may collect additional personal information in the course of job-related activities throughout the period you work for Us. This can be in the form of information you provide directly to Us or information that We collect automatically about you, such as from monitoring computer access and usage.
Use of Personal Information
We use this Personal Information for the purposes of operating, managing, and maintaining Our business, managing our workforce, and accomplishing our business purposes and objectives, including, for example, to:
- Human resources and personnel management. Manage workforce activities and personnel generally, including for recruitment, background screening, hiring, performance management, discipline, career development, employee training, leaves, and promotions.
- Business process execution and internal management. Schedule work; record time; manage Heineken USA and employee assets; conduct internal audits and investigations; review and monitor compliance with internal policies and procedures; implement business controls and use employee directories; provide an efficient means for personnel to obtain the contact information of their colleagues so they may contact them; perform identity verification, accounting, audit, and other internal functions; monitoring compliance with training and other policies; conduct research, analytics, and data analysis to assist in planning succession and to ensure business continuity, as well as to design employee retention programs and diversity initiatives; record phone calls for training, quality assurance, and legal compliance purposes; operate and manage IT and communications systems and facilities; undertake strategic planning and project management; and obtain legal advice and establish, exercise or defend legal rights.
- Compliance with law. Comply with legal and regulatory obligations; act on collection and discovery requests in the context of litigation, government investigations or regulatory audits or inquiries; comply with legal process, investigations, and other requirements such as income tax deductions, monitoring, record-keeping and reporting obligations; use information for insurance purposes; and prepare for and engage in dispute resolution.
- Health, Safety, Security, and Integrity. Protect the interests of Heineken and its employees, including screening of employees, and authentication of employee status, access rights, and identity management; notify family members in case of emergency; maintain and secure Our facilities, equipment, systems, and infrastructure; undertake quality and safety assurance measures to protect the health and safety of Our workforce and others; monitor use of IT infrastructure, internet access, and electronic communication for unauthorized, unlawful, or inappropriate use.
- Payroll and Benefits. Manage payroll, wages, tax forms and filings, expense reimbursements, and other awards such as bonuses, and provide healthcare, pensions, calculate insurance and other employee benefits, savings plans and other benefits.
Disclosure of Your Personal Information
We may disclose personal information that We collect or that you provide as described in this Privacy Policy:
- To our affiliates, subsidiaries, and other Heineken companies.
- To service providers, which are companies We use to support our business and who are bound by law and contractual obligations to keep your personal information confidential. Service providers may use information We share with them only for the purposes for which We disclose it to them and as otherwise permitted by law. The categories of service providers that we share information with are:
- Payroll services providers that assist us in calculating and disbursing your salary and other compensation.
- Auditing and accounting firms, such as firms that assist us in the creation of our financial records.
- Professional services consultants, such as firms that perform analytics, assist with improving our business, provide legal services, or supply project-based resources and assistance.
- Recruitment vendors that assist with the application process, including assessing candidate qualifications and providing the platform through which candidates submit their candidacy.
- Analytics services, including entities that analyze traffic to and on our website and assist with identifying and communicating with potential customers.
- Security vendors, such as entities that assist with security incident verification and response, service notifications, and fraud prevention.
- IT vendors, such as entities that assist with website design, hosting and maintenance; data and software storage; and network operation.
- Benefits providers, such as life insurance, health insurance and gym membership service providers.
- To other external parties when required by law or to protect Heineken or other persons, as described in this privacy notice.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Heineken’s assets or capital stock, whether as a going concern or as part of bankruptcy, liquidation or a similar proceeding, in which personal information held by Heineken about Our employees, workers, and contractors is among the assets transferred. If this happens, the recipient of the personal information will continue to honor the promises made in this privacy notice, or else provide you notice of any changes.
We do not sell your personal information to or share your personal information with any third parties for behavioral advertising purposes. However, We may disclose aggregated or deidentified information without restriction.
Access to Your Personal Information
Members of staff have access to your personal information where appropriate to perform their job. These staff members may include HR, Legal, IT, Finance and Audit. Your business contact information such as name, position, telephone number, postal address of your location and business email address, and shall generally be available to all Heineken employees for internal communication purposes.
We may also disclose personal information to other entities in the context of performing any of the purposes for using personal information set out above. These entities may include:
- HEINEKEN group companies for the purpose of providing central processing facilities, due to the global nature of HEINEKEN shared IT systems;
- Service providers to enable them to provide Us with products or a service. These products and services may include payroll, benefits providers, IT systems suppliers, travel services, performance management, training, expense management or credit card companies, medical / health practitioners and background check agencies;
- Professional advisors (such as accountants, auditors, or lawyers);
- Entities in the course of the sale of all or some of the assets or shares of a HEINEKEN group company; and
- Law enforcement bodies (including but not limited to regulatory authorities, public bodies, immigration authorities, and judicial bodies) in order to comply with any legal obligation or court order or when we, in good faith, believe we are legal authorized to do so.
Retention
We will retain your personal information for as long as legally required or for as long as necessary for any of the purposes listed in this Privacy Notice, or to comply with legal requirements that we are subject to, as long as reasonably necessary for archiving purposes or as long as advisable in light of an applicable statute of limitations. We will take reasonable steps to destroy or de-identify personal information We hold if it is no longer needed for the purposes set out above or after the expiration of the defined retention term.
Employees’ Obligations and Rights
Please keep your personal information up to date and inform Us of any significant changes. You agree to inform your dependents whose personal information you provide to Us about the content of this Privacy Notice and ensure you have the right to provide that information to Us.
Special Information for California Residents
The California Consumer Protection Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), provides California residents, referred to in the law as “consumers,” with rights to receive certain disclosures regarding the collection, use, and sharing of personal information, as well as rights to request to access, correct, and delete personal information, as well as to opt out of the “sale” or “sharing” of their personal information, as those terms are defined in the CCPA. The CCPA defines “personal information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular” California resident. Certain information we collect may be exempt from the CCPA because it is considered publicly available information or covered by a federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.
To the extent that we collect personal information about you that is subject to the CCPA, that information, our practices, and your rights are described in the below disclosures.
Right to Information Regarding the Categories of Personal Information Collected, Sold, Shared, and Disclosed
You have the right to obtain information regarding the categories of personal information, including sensitive personal information, We collect, sell, share, or disclose. That information is provided in this privacy notice. We collect the categories of information described in the Information We Collect About You section above. The categories We use to describe the information are those enumerated in the CCPA.
Right to Request Access, Correction, and Deletion of Information
You have the right to request access to personal information collected about you and information regarding the source of that personal information, the purposes for which We collect it, and the third parties and services providers to whom We sell, share, or disclose it, if any. You also have the right to request in certain circumstances that We correct personal information that We have collected about you and to delete personal information that We have collected directly from you. These rights are subject to applicable exceptions. To request to exercise these rights, please contact us by clicking here or call us at 1-833-983-5070.
Right to Information Regarding Participation in Data Sharing for Financial Incentives
We may run promotions from time to time whereby we incentivize an employee, worker or contractor to share certain pieces of information with Us. Participation in any of these incentives is voluntary, and you may opt out of the data sharing at any time.
Right to Opt Out of Sale or Sharing of Personal Information to Third Parties
The CCPA defines “selling” personal information as disclosing it to an external party for monetary or other benefit. “Sharing” is defined as the disclosure of Personal Information to a third party for “cross context behavioral advertising,” whether or not for monetary or other valuable consideration. We currently do not sell your personal information to, or share your personal information with, any third parties. Please note that the right to opt out does not apply to Our sharing of data with service providers, who are parties We engage to perform a function on our behalf and are legally and contractually obligated to use the data only for that function or as otherwise permitted by law.
Changes to this Notice
We may change or update this Notice from time to time. When we do, we will post the revised Notice with a new “Last Updated” date.
Contact Us
You have a question or concern regarding this Privacy Policy, please send an e-mail to [email protected].