Introduction

Welcome to Star Pubs & Bars Limited's privacy notice.

We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit this website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Star Pubs & Bars collects and processes your personal data through your use of this website, including any data you may provide through this website.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

Star Pubs & Bars Limited is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy notice).  Star Pubs & Bars is part of the Heineken group.

Contact details

Our full details are:

Star Pubs & Bars Limited 
3-4 Broadway Park
South Gyle Broadway
Edinburgh
EH12 9JZ
United Kingdom

protectingyourdata@heineken.co.uk

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated in May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name, username or similar identifier and date of birth.
  • Contact Data includes address, email address and telephone numbers.
  • Technical Data includes internet protocol (IP) address, mobile device ID, any login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Applicant Data includes information you provide when applying to become a licensee in one of our pubs. 
  • Usage Data includes information about how you use this website and/or services.
  • Communications Data includes your preferences in receiving communications from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply to become a licensee in one of our pubs;
  • create an account on this website;
  • subscribe to our communications; or
  • give us some feedback.
  • Automated technologies or interactions. As you interact with this website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
  • Third party sources. We may receive Technical Data from analytics providers such as Google based outside the European Economic Area (“EEA”).  We may receive Identity and Contact Data from third parties you have used for verification purposes when accessing this website, such as social media providers and Google based outside the EEA.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.
  • Where we have asked you for your express opt-in consent.

Please see the Glossary at paragraph 10 to find out more about the types of lawful basis that we will rely on to process your personal data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at protectingyourdata@heineken.co.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose / Activiy Type of data Lawful basis for processing including basis of legitimate interest Retention period
To respond to any enquiries you have submitted via this website (a) Identity, (b) Contact Performance of a contract with you 3 years after the enquiry has been dealt with
To process your application to become a licensee in one of our pubs (a) Identity, (b) Contact, (c) Applicant Necessary for our legitimate interests (recruitment of licensees and internal administration) 6 months after notification to you that your application was successful / unsuccessful
To register you as a new licensee if your application is successful (a) Identity, (b) Contact, (c) Applicant Performance of a contract with you (a) For irrelevant information (i.e. information which has no bearing on the on-going relationship), 6 months after notification to you that your application was successful, (b) for relevant information, 6 years following the termination of the relationship
To add unsuccessful applications to our talent bank of excellent candidates so that we can contact you when suitable opportunities to license one of our pubs arise (a) Identity, (b) Contact, (c) Applicant Consent, where expressly provided by you 1 year after notification to you that your application was unsuccessful
To manage our relationship with you (when you create an account on this website and/or register for communications) which will include: (a) Notifying you about changes to our terms or privacy policy, (b) Sending you communications you have requested (a) Identity, (b) Contact, (c) Communications (a) Performance of a contract with you, (b) Necessary to comply with a legal obligation, (c) Necessary for our legitimate interests (to keep our records updated) Until you opt out of receiving communications and/or no longer have an account with us
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity, (b) Contact, (c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise), (b) Necessary to comply with a legal obligation 26 months from website visit
To use data analytics to improve this website, services, marketing, licensee relationships and experiences (a) Technical, (b) Usage Necessary for our legitimate interests (to define types of licensees for our services, to keep this website updated and relevant, to develop our business and to inform our marketing strategy) 26 months from website visit

Communications

You will receive communications from us if you have requested information from us and have not opted out of receiving that communication.

Opting out

You can ask us to stop sending you communications at any time by logging into the website and checking or unchecking relevant boxes to adjust your communication preferences or by following the opt-out links on any message sent to you.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, Please see our cookie policy for further details.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at protectingyourdata@heineken.co.uk.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

Internal third parties

  • Other companies in the Heineken group based within the EEA.

External third parties

  • IT and system administration service providers based outside the EEA.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Our external third parties may be based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us at protectingyourdata@heineken.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are set out in the table in paragraph 4 above.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary at paragraph 10 to find out more about these rights. If you wish to exercise any of the rights set out, please contact us at protectingyourdata@heineken.co.uk

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at us at protectingyourdata@heineken.co.uk.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Consent means we have asked you for your express opt-in consent to use your personal data for a specific purpose.  You have the right to withdraw consent to marketing at any time by contacting us at protectingyourdata@heineken.co.uk.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

No entry for underage persons

This Website is intended only for persons of legal drinking age. Do not use this Website if you are not of legal drinking age. Date of birth verification may be required at the entrance of the Website and prompts may be located within the Website.

Accessing our site

Access to our site is permitted on a temporary basis, and we reserve the right to withdraw or amend the service we provide on our site without notice. We will not be liable if for any reason our site is unavailable at any time or for any period.

From time to time, we may restrict access to some parts of our site, or our entire site, to users who have registered with us.

If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential, and you must not disclose it to any third party. We have the right to disable any user identification code or password, whether chosen by you or allocated by us, at any time, if in our opinion you have failed to comply with any of the provisions of these terms of use.

You are responsible for making all arrangements necessary for you to have access to our site. You are also responsible for ensuring that all persons who access our site through your internet connection are aware of these terms, and that they comply with them.​

Privacy policy updates

By using our website, you signify your acceptance of this Privacy Policy. Star Pubs & Bars reserves the right to modify, alter or otherwise update this policy at any time.

Legal purchase age

You must not provide us with your personal information if you are not of legal age to purchase alcohol in the jurisdiction in which you reside and (if different) in the jurisdiction in which you are accessing the site. We do not intend to collect personal information from any individuals under the legal purchase age or market alcohol beverages to anyone under the legal purchase age. If we receive notice or believe that someone under the legal purchase age has provided us with personal information we will make every reasonable effort to remove such personal information from our files.

Links and third parties

Our website often provides links to resources that we believe may be useful. These links will lead you to websites operated by third parties that operate under different privacy policies. We encourage you to review those privacy policies, as we have no control over information you may submit to those third parties.

Our website may use third parties, such as ad server companies, to present or serve advertisements that you may see on our website. Our website may also include advertisements placed by third parties. Our privacy policy does not cover any information collected by those third parties nor does it cover how they may use such information.

You may link to our home page, provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in such a way as to suggest any form of association, approval or endorsement on our part where none exists. You must not establish a link from any website that is not owned by you.

Our site must not be framed on any other site, nor may you create a link to any part of our site other than the home page. We reserve the right to withdraw linking permission without notice.

Viruses

Our website is not guaranteed to be free from any so-called computer viruses and it is recommended that you check for any such viruses before downloading it to your computer.

Copyright and trade marks

This site contains material which is owned by Star Pubs & Bars and is protected by international copyright, trade mark and other intellectual property laws. No permission is given by Star Pubs & Bars in respect of the reproduction or use for commercial purposes of any brand names, product names, designs and other materials shown in which intellectual property rights subsist. You are only entitled to copy electronically and print hard copy portions of the website for the sole purpose of viewing and purchasing products of Star Pubs & Bars.

Star Pubs & Bars is licensed to reproduce and distribute the sound and video recordings contained on this website. You are only permitted to download such sound and video recordings for person viewing in the UK. You are expressly prohibited from sharing such sound and video recordings.

Reliance on information posted

Commentary and other materials posted on our site are not intended to amount to advice on which reliance should be placed. We therefore disclaim all liability and responsibility arising from any reliance placed on such materials by any visitor to our site, or by anyone who may be informed of any of its contents.

Our site changes regularly

We aim to update our site regularly, and may change the content at any time. If the need arises, we may suspend access to our site, or close it indefinitely. Any of the material on our site may be out of date at any given time, and we are under no obligation to update such material.

Our liability

The material displayed on our site is provided without any guarantees, conditions or warranties as to its accuracy. To the extent permitted by law, we, other members of our group of companies and third parties connected to us hereby expressly exclude:

  • All conditions, warranties and other terms which might otherwise be implied by statute, common law or the law of equity.
  • Any liability for any direct, indirect or consequential loss or damage incurred by any user in connection with our site or in connection with the use, inability to use, or results of the use of our site, any websites linked to it and any materials posted on it, including, without limitation any liability for:
  • loss of income or revenue;
  • loss of business;
  • loss of profits or contracts;
  • loss of anticipated savings;
  • loss of data;
  • loss of goodwill;
  • wasted management or office time; and for any other loss or damage of any kind, however arising and whether caused by tort (including negligence), breach of contract or otherwise, even if foreseeable, provided that this condition shall not prevent claims for loss of or damage to your tangible property or any other claims for direct financial loss that are not excluded by any of the categories set out above.

This does not affect our liability for death or personal injury arising from our negligence, nor our liability for fraudulent misrepresentation or misrepresentation as to a fundamental matter, nor any other liability which cannot be excluded or limited under applicable law.

Location and jurisdiction

This site is hosted by IBM in the USA but controlled and operated by Star Pubs & Bars from its offices in the UK.  Personal data is stored on the IBM Kenexa Brassring System on servers in Dublin.  Star Pubs & Bars makes no representation that material in the site is appropriate or available for use in other locations. Those who choose to access this site from other locations do so on their own initiative and are responsible for compliance with local laws if, and to the extent that local laws are applicable.

These terms and conditions and anything in this site shall be governed by the laws of Scotland.

Information about us

Star Pubs & Bars Limited is registered in Scotland under company number SC0250925 and have our registered office at 3-4 Broadway Park, EDINBURGH, EH12 9JZ. Our VAT number is GB268644912.

Questions or comments?

If you have any further questions or comments regarding our Privacy Policy, please send us an e-mail with your questions or comments.

This Website Privacy Policy was last updated in May 2018.