Molson Group Privacy Policy

1. Introduction

1.1 We
are committed to safeguarding the privacy of our website visitors.

1.2 This
policy applies where we are acting as a data controller with respect to the
personal data of our website visitors; in other words, where we determine the
purposes and means of the processing of that personal data.

1.3 We
use cookies on our website. Insofar as those cookies are not strictly necessary
for the provision of our website, we will ask you to consent to our use of
cookies when you first visit our website.

1.4 Our
website incorporates privacy controls which affect how we will process your
personal data. By using the privacy controls, you can specify whether you would
like to receive direct marketing communications. You can access the privacy
controls via https://www.molsongroup.co.uk/contact

1.5 In
this policy, “we”, “us” and “our” refer to Molson
Group. For more information about us, see Section 13.

2. Credit

2.1 This
document was created using a template from SEQ Legal (https://seqlegal.com).

You must retain the above credit. Use of this document without the credit is an infringement of copyright. However, you can purchase from us an equivalent document that does not include the credit.

3. How we use your personal data

3.1 In
this Section 3 we have set out:

(a) the
general categories of personal data that we may process;

(b) [in
the case of personal data that we did not obtain directly from you, the source
and specific categories of that data];

(d) the
legal bases of the processing.

3.2 We
may process data about your use of our website (“usage data“).
The usage data may include your IP address, geographical location, browser type
and version, operating system, referral source, length of visit, page views and
website navigation paths, as well as information about the timing, frequency and
pattern of your service use. The source of the usage data is our analytics
tracking system. This usage data may be processed for the purposes of analysing
the use of the website. The legal basis for this processing is legitimate
interests, namely monitoring and improving our website and services.

3.3 We
may process your account data (“account data“). The account data
may include your name and email address. The account data may be processed for
the purposes of operating our website, providing our services, ensuring the
security of our website and services, maintaining back-ups of our databases and
communicating with you. The legal basis for this processing is legitimate
interests, namely the proper administration of our website and business.

3.4 We
may process your personal data that are provided in the course of the use of
our services (“service data“). The source of the service data
is you or your employer. The service data may be processed for the purposes of
operating our website, providing our services, ensuring the security of our
website and services, maintaining back-ups of our databases and communicating
with you. The legal basis for this processing is legitimate interests, namely the
proper administration of our website and business.

3.5 We
may process information that you post for publication on our website or through
our services (“publication data“). The publication data may be
processed for the purposes of enabling such publication and administering our
website and services. The legal basis for this processing is legitimate interests,
namely the proper administration of our website and business.

3.6 We
may process information contained in any enquiry you submit to us regarding
goods and/or services (“enquiry data“). The enquiry data may
be processed for the purposes of offering, marketing and selling relevant goods
and/or services to you. The legal basis for this processing is legitimate
interests, namely the proper administration of our website and business.

3.7 We
may process information relating to our customer relationships, including
customer contact information (“customer relationship data“).
The customer relationship data may include your name, your employer, your job
title or role, your contact details, and information contained in
communications between us and you or your employer. The source of the customer
relationship data is you or your employer. The customer relationship data may
be processed for the purposes of managing our relationships with customers,
communicating with customers, keeping records of those communications and
promoting our products and services to customers. The legal basis for this
processing is legitimate interests, namely the proper management of our
customer relationships.

3.8 We
may process information that you provide to us for the purpose of subscribing
to our email notifications and/or newsletters (“notification data“).
The notification data may be processed for the purposes of sending you the
relevant notifications and/or newsletters. The legal basis for this processing
is consent.

3.9 We
may process information contained in or relating to any communication that you
send to us (“correspondence data“). The correspondence data
may include the communication content and metadata associated with the
communication. Our website will generate the metadata associated with
communications made using the website contact forms. The correspondence data
may be processed for the purposes of communicating with you and record-keeping.
The legal basis for this processing is our legitimate interests, namely the
proper administration of our website and business and communications with users.

3.10 We
may process any of your personal data identified in this policy where necessary
for the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure. The legal basis
for this processing is our legitimate interests, namely the protection and
assertion of our legal rights, your legal rights and the legal rights of others.

3.11 We
may process any of your personal data identified in this policy where necessary
for the purposes of obtaining or maintaining insurance coverage, managing
risks, or obtaining professional advice. The legal basis for this processing is
our legitimate interests, namely the proper protection of our business against
risks.

3.12 In
addition to the specific purposes for which we may process your personal data
set out in this Section 3, we may also process any of your personal data where
such processing is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital interests
of another natural person.

3.13 Please
do not supply any other person’s personal data to us, unless we prompt you to
do so.

4. Providing your personal data to others

4.1 We
may disclose your personal data to any member of our group of companies (this
means our subsidiaries, our ultimate holding company and all its subsidiaries)
insofar as reasonably necessary for the purposes, and on the legal bases, set
out in this policy.

4.2 We
may disclose your personal data to our insurers and/or professional advisers
insofar as reasonably necessary for the purposes of obtaining or maintaining
insurance coverage, managing risks, obtaining professional advice, or the
establishment, exercise or defence of legal claims, whether in court proceedings
or in an administrative or out-of-court procedure.

4.3 We
may disclose your enquiry data to one or more of those selected third party
suppliers of goods and services identified on our website for the purpose of enabling
them to contact you so that they can offer, market and sell to you relevant
goods and/or services. Each such third party will act as a data controller in
relation to the enquiry data that we supply to it; and upon contacting you,
each such third party will supply to you a copy of its own privacy policy,
which will govern that third party’s use of your personal data.

4.4 In
addition to the specific disclosures of personal data set out in this Section
4, we may disclose your personal data where such disclosure is necessary for
compliance with a legal obligation to which we are subject, or in order to
protect your vital interests or the vital interests of another natural person.
We may also disclose your personal data where such disclosure is necessary for
the establishment, exercise or defence of legal claims, whether in court
proceedings or in an administrative or out-of-court procedure.

5. International transfers of your personal
data

5.1 In
this Section 5, we provide information about the circumstances in which your
personal data may be transferred to countries outside the European Economic
Area (EEA).

5.2 We
and our other group companies have offices and facilities in England and
Scotland. The European Commission has made an “adequacy decision”
with respect to [the data protection laws of each of these countries. Transfers
to each of these countries will be protected by appropriate safeguards, namely
[the use of standard data protection clauses adopted or approved by the
European Commission, a copy of which can be obtained from the use of binding
corporate rules.

5.3 The
hosting facilities for our website are situated in England. The European
Commission has made an “adequacy decision” with respect to the data
protection laws of each of these countries. Transfers to each of these
countries will be protected by appropriate safeguards, namely the use of
standard data protection clauses adopted or approved by the European Commission.

5.4 You
acknowledge that personal data that you submit for publication through our
website or services may be available, via the internet, around the world. We
cannot prevent the use (or misuse) of such personal data by others.

6. Retaining and deleting personal data

6.1 This
Section 6 sets out our data retention policies and procedure, which are
designed to help ensure that we comply with our legal obligations in relation
to the retention and deletion of personal data.

6.2 Personal
data that we process for any purpose or purposes shall not be kept for longer
than is necessary for that purpose or those purposes.

6.3 We
will retain your personal data as follows:

(a) personal
data category or categories will be retained for a minimum period of two
years following date of data capture and for a maximum period of five
years following date of data capture.

6.4 In
some cases it is not possible for us to specify in advance the periods for
which your personal data will be retained.

6.5 Notwithstanding
the other provisions of this Section 6, we may retain your personal data where
such retention is necessary for compliance with a legal obligation to which we
are subject, or in order to protect your vital interests or the vital interests
of another natural person.

7. Amendments

7.1 We
may update this policy from time to time by publishing a new version on our
website.

7.2 You
should check this page occasionally to ensure you are happy with any changes to
this policy.

7.3 We
may notify you of significant changes to this policy by email.

8. Your rights

8.1 In
this Section 8, we have summarised the rights that you have under data protection
law. Some of the rights are complex, and not all of the details have been
included in our summaries. Accordingly, you should read the relevant laws and
guidance from the regulatory authorities for a full explanation of these
rights.

8.2 Your
principal rights under data protection law are:

(a) the
right to access;

(b) the
right to rectification;

(d) the
right to restrict processing;

(e) the
right to object to processing;

(f) the
right to data portability;

(g) the
right to complain to a supervisory authority; and

(h) the
right to withdraw consent.

8.3 You
have the right to confirmation as to whether or not we process your personal
data and, where we do, access to the personal data, together with certain
additional information. That additional information includes details of the
purposes of the processing, the categories of personal data concerned and the
recipients of the personal data. Providing the rights and freedoms of others
are not affected, we will supply to you a copy of your personal data. The first
copy will be provided free of charge, but additional copies may be subject to a
reasonable fee.

8.4 You
have the right to have any inaccurate personal data about you rectified and,
taking into account the purposes of the processing, to have any incomplete
personal data about you completed.

8.5 In
some circumstances you have the right to the erasure of your personal data
without undue delay. Those circumstances include: the personal data are no
longer necessary in relation to the purposes for which they were collected or
otherwise processed; you withdraw consent to consent-based processing; you
object to the processing under certain rules of applicable data protection law;
the processing is for direct marketing purposes; and the personal data have
been unlawfully processed. However, there are exclusions of the right to
erasure. The general exclusions include where processing is necessary: for
exercising the right of freedom of expression and information; for compliance
with a legal obligation; or for the establishment, exercise or defence of legal
claims.

8.6 In
some circumstances you have the right to restrict the processing of your
personal data. Those circumstances are: you contest the accuracy of the
personal data; processing is unlawful but you oppose erasure; we no longer need
the personal data for the purposes of our processing, but you require personal
data for the establishment, exercise or defence of legal claims; and you have
objected to processing, pending the verification of that objection. Where
processing has been restricted on this basis, we may continue to store your
personal data. However, we will only otherwise process it: with your consent;
for the establishment, exercise or defence of legal claims; for the protection
of the rights of another natural or legal person; or for reasons of important
public interest.

8.7 You
have the right to object to our processing of your personal data on grounds
relating to your particular situation, but only to the extent that the legal
basis for the processing is that the processing is necessary for: the
performance of a task carried out in the public interest or in the exercise of
any official authority vested in us; or the purposes of the legitimate
interests pursued by us or by a third party. If you make such an objection, we
will cease to process the personal information unless we can demonstrate
compelling legitimate grounds for the processing which override your interests,
rights and freedoms, or the processing is for the establishment, exercise or
defence of legal claims.

8.8 You
have the right to object to our processing of your personal data for direct
marketing purposes (including profiling for direct marketing purposes). If you
make such an objection, we will cease to process your personal data for this
purpose.

8.9 You
have the right to object to our processing of your personal data for scientific
or historical research purposes or statistical purposes on grounds relating to
your particular situation, unless the processing is necessary for the
performance of a task carried out for reasons of public interest.

8.10 To
the extent that the legal basis for our processing of your personal data is:

(a) consent;
or

(b) that
the processing is necessary for the performance of a contract to which you are
party or in order to take steps at your request prior to entering into a
contract,

and
such processing is carried out by automated means, you have the right to
receive your personal data from us in a structured, commonly used and machine-readable
format. However, this right does not apply where it would adversely affect the
rights and freedoms of others.

8.11 If
you consider that our processing of your personal information infringes data
protection laws, you have a legal right to lodge a complaint with a supervisory
authority responsible for data protection. You may do so in the EU member state
of your habitual residence, your place of work or the place of the alleged
infringement.

8.12 To
the extent that the legal basis for our processing of your personal information
is consent, you have the right to withdraw that consent at any time. Withdrawal
will not affect the lawfulness of processing before the withdrawal.

8.13 You
may exercise any of your rights in relation to your personal data by written
notice to us in addition to the other methods specified in this Section 8.

9. About cookies

9.1 A
cookie is a file containing an identifier (a string of letters and numbers)
that is sent by a web server to a web browser and is stored by the browser. The
identifier is then sent back to the server each time the browser requests a
page from the server.

9.2 Cookies
may be either “persistent” cookies or “session” cookies: a
persistent cookie will be stored by a web browser and will remain valid until
its set expiry date, unless deleted by the user before the expiry date; a
session cookie, on the other hand, will expire at the end of the user session,
when the web browser is closed.

9.3 Cookies
do not typically contain any information that personally identifies a user, but
personal information that we store about you may be linked to the information
stored in and obtained from cookies.

10. Cookies that we use

10.1 We
use cookies for the following purposes:

(a) authentication
– we use cookies to identify you when you visit our website and as you navigate
our website.

(b) status
– we use cookies to help us to determine if you are logged into our website.

(c) security
– we use cookies as an element of the security measures used to protect user
accounts, including preventing fraudulent use of login credentials, and to
protect our website and services generally.

(d) analysis
– we use cookies to help us to analyse the use and performance of our website
and services.

(g) cookie
consent – we use cookies to store your preferences in relation to the use of
cookies more generally.

11. Cookies used by our service providers

11.1 Our
service providers use cookies and those cookies may be stored on your computer
when you visit our website.

11.2 We
use Google Analytics to analyse the use of our website. Google Analytics
gathers information about website use by means of cookies. The information
gathered relating to our website is used to create reports about the use of our
website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/

12. Managing cookies

12.1 Most
browsers allow you to refuse to accept cookies and to delete cookies. The
methods for doing so vary from browser to browser, and from version to version.
You can however obtain up-to-date information about blocking and deleting
cookies via these links:

(a) https://support.google.com/chrome/answer/95647?hl=en
(Chrome);

(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
(Firefox);

(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
(Internet Explorer);

(e) https://support.apple.com/en-lk/guide/safari/sfri11471/16.0/mac/11.0 (Safari); and

(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
(Edge).

12.2 Blocking
all cookies will have a negative impact upon the usability of many websites.

12.3 If
you block cookies, you will not be able to use all the features on our website.

13. Our details

13.1 This
website is owned and operated by Molson Group.

13.2 We
are registered in England and Wales under registration number 6378361,
and our registered office is at Smoke Lane, Avonmouth, Bristol, BS11 0YA.

13.3 Our
principal place of business is at Smoke Lane, Avonmouth, Bristol, BS11 0YA.

13.4 You
can contact us:

(a) by
post, to the postal address given above;

(b) using
our website contact form;

(d) by
email, using the email address published on our website from time to time.

14. Data protection officer

14.1 Our data protection officer’s contact details are:

Annalea Ormiston, Group Head of People

Rhys Gardner, Molson Group Finance Director