PRIVACY POLICY IN THE OFFICIAL SOCIAL NETWORKS OF CERVEZA VICTORIA 1928, SL

1. INTRODUCTION

This Social Networks Privacy Policy describes the use that CERVEZA VICTORIA 1928, S.L. (hereinafter, CERVEZA VICTORIA) makes of users’ personal data when they register via CERVEZA VICTORIA profiles on the social networks of Facebook, Twitter, etc., and when the users browse these sites with their social network user, for the purposes listed below.

When users register with their ID on Facebook, Twitter, or any type of social network, they give their consent to the processing of their personal data, in accordance with the Privacy Policy of CERVEZA VICTORIA.

2. PERSONAL DATA PROTECTION: IDENTIFICATION OF THE DATA CONTROLLER

Users who provide their personal data with the information available via their account and/or their user profile on social networks owned by CERVEZA VICTORIA, are informed that CERVEZA VICTORIA is the Data Controller, unless other terms and conditions with regard to particular processing are otherwise expressly stated.

In accordance with what is set forth in the applicable data protection laws, CERVEZA VICTORIA respects the privacy of users and the confidentiality and security of personal data, by adopting the legal, technical and organisational measures necessary to prevent the loss, misuse, modification, unauthorised access and theft of personal data, taking into account the technological conditions, the nature of the data and the risks to which they are exposed.

The users’ personal data will only be collected by CERVEZAS VICTORIA 1928, S.L. for processing when it is appropriate, relevant and non-excessive in relation to the scope and purposes for which it was obtained. Thus, the processing will be limited to the purposes that the users are informed of in each case.

When personal data is collected, the user shall be informed in advance in a clear and unequivocal way of the circumstances relating to the processing of their data, in accordance with the requirements on data protection in force at any given time. In addition, the personal data provided to CERVEZA VICTORIA will be retained for as long as the data subject (i) does not request its erasure or modification, (ii) does not object to their data will continue to be processed, or (iii) when the processing requires their authorisation, does not withdraw their consent. Notwithstanding the foregoing, and in addition to the above-mentioned terms, the data shall be securely stored, and made available exclusively to judges and the courts, the Public Prosecutor or the competent Public Authorities, in particular the data protection authorities, during a period of 3 years in order to deal with any potential claims that may arise from the use made of said data.

For more details in relation to the processing of their personal data, the user must refer to the CERVEZA VICTORIA Privacy Policy page, where they will find detailed information regarding data protection.

Privacy Policy

3. DATA REGARDING MINORS OR LEGALLY INCAPACITATED PERSONS

Access and registration via the CERVEZA VICTORIA social networks is prohibited for minors under the age of 18. In the event that the user is legally incapacitated, the intervention of someone who holds parental authority or guardianship of the user, or their legal representative, shall be required via a valid document which verifies the legal representation status of the legally incapacitated user in order to gain access.

CERVEZA VICTORIA is expressly released from any liability that may arise from the use of social networks by minors or legally incapacitated persons. CERVEZA VICTORIA social networks do not purposely collect any personal information regarding minors, therefore, if the user is a minor, they should not register, or use CERVEZA VICTORIA social networks or provide any personal information.

4. INTENDED PURPOSES OF THE DATA ON SOCIAL NETWORKS

The information and personal data provided voluntarily by the user via CERVEZA VICTORIA social networks is processed for the purpose of:

· Managing the user's registration and creating their account and their use of CERVEZA VICTORIA social networks.

· Responding to any requests made via CERVEZA VICTORIA social networks.

· Sending information and advertising from CERVEZA VICTORIA, by any means, electronic or otherwise.

· Finding out the opinion and rating of the user and keeping them up to date on activities, news, special offers and promotions about the CERVEZA VICTORIA brand they are interested in.

· Sending information, advertising and product offers, services and activities in the field of food and beverages, by any means, including electronic (e-mail or equivalent means, such as SMS, by telephone or mobile phone). All this shall be on the condition that the data subject has expressly given their consent thereto.

· Finding out the opinion and rating of the user and keeping them up to date on activities, news, special offers and promotions about the CERVEZA VICTORIA brand they are interested in.

· Analysing and creating commercial profiles based on the information provided in order to find content that is of interest to the user, using profiling techniques to carry out targeted advertising and direct marketing. The creation of these profiles will be based on information from both CERVEZA VICTORIA internal sources as well as external ones, such as social networks, public sources, other companies belonging to the group or partner companies. All of the above shall be on the condition that the data subject has given their consent thereto.

The information provided by the user via CERVEZA VICTORIA social networks, including personal data, may be published, always depending on which services the user makes use of; it may, therefore, be made available to the public by third-party users of the social networks. Using the profile settings of each social network, the user can establish what information they wish to make public in each case, see what permissions are granted, remove or disable said permissions, as they would with any third-party application they no longer wish to use.

If the CERVEZA VICTORIA app is expressly deactivated, or the third-party permissions in the user’s profile on a social networking site are disabled, the user ID for the social network will no longer be available.

The user may share texts, photos, videos and other information or other and/or content in social networks, doing so voluntarily and consciously and of their own free will. If they do so, such content will be subject to this Policy, as well as to the Terms and Conditions of Access and Use of the social network in question. The user shall be responsible for ensuring that all the contents they publish comply with the law in force, this policy and with the legal notice contained herein. The user may only publish personal data, photographs and information or other contents which belong to them and for which they hold the ownership rights, or for which they have received authorisation from third parties.

CERVEZA VICTORIA reserves the right to remove from its official page, unilaterally and without prior notice to or authorisation from the user, any contents the user might publish that infringe or breach the law in force, the regulations set forth in this policy and/or those of the social networks.

5. LIABILITY AND QUALITY OF THE DATA

CERVEZA VICTORIA is only liable for and guarantees the confidentiality, security and processing of the data in accordance with this policy in respect of personal data that are collected from the registered user through their ID on the social network. It shall not be held liable with regard to the processing and subsequent uses made of the personal data that may be carried out both by the owner of the social network, such as by third-party information company service providers unrelated to CERVEZA VICTORIA that may access such data in the providing of their services or carrying out their activity or third parties that set up hyperlinks on the social network.

CERVEZA VICTORIA warns that no user may use the identity of another person and/or disclose personal data relating to third parties without first having obtained their permission. Therefore, the user must keep in mind at all times that they may only provide their own personal data corresponding to their own identity and that the said data must be appropriate, relevant, current, accurate and true. In any case, the user must respect the privacy of third parties, whether they are users of the CERVEZA VICTORIA social network or not.

6. EXERCISING PERSONAL DATA PROTECTION RIGHTS

CERVEZA VICTORIA hereby informs the user of the possibility of exercising the following rights:

- To request access to their personal data which is being processed and receive such information in writing in the requested format.

- To request the rectification of inaccurate data, or, where appropriate, request their erasure when, for among other reasons, the data is no longer necessary for the purposes for which they were collected.

- To request the restriction of the processing of their data.

- To object to the processing of their personal data where appropriate.

- To request the portability of their personal data where the processing is based on consent and is carried out by automated means. In these instances, the data shall be provided to the user in a structured, common and machine-readable format.

- Withdraw the consent given.

- To make a complaint to the Spanish Data Protection Agency.

The user may exercise the aforementioned rights by writing to the following address: CERVEZA VICTORIA S.A. F.A.O. OFICINA PRIVACIDAD, Avda. Velázquez, 215, 29004 MALAGA), or via the following e-mail address: privacidad@cervezavictoria.es

7. OTHER RELEVANT INFORMATION

CERVEZA VICTORIA may modify and/or replace this policy at any time which, as the case may be, will replace, complete and/or modify the one published herein. In these cases, if the user was registered, CERVEZA VICTORIA must inform them directly regarding any possible changes that may affect them legally, as well as access to the policy at all times in order to stay informed and up to date.

The user may contact CERVEZA VICTORIA via the internal messaging service which forms part of the social network or by using the following contact details:

CERVEZA VICTORIA 1928, S.L.

Address: Avda. Velázquez nº 215 - 29004 MÁLAGA