Maltina Nourishment Tour
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    Privacy Notice

    General

    Maltina is a brand of Nigerian Breweries Plc, with its registered office at No. 1 Abebe Village Road, Iganmu, Lagos, Nigeria (“Maltina”, “NB”, “we”, “us” or “our”). Nigerian Breweries Plc is the controller responsible for the processing of personal data collected through the Maltina website and related Maltina platforms, activities, events, and digital channels (together, the “Platforms”).

    We respect your privacy and are committed to keeping your personal data secure and managing it in accordance with our obligations under the Nigerian Data Protection Act, 2023 (NDPA) and other applicable data protection laws.

    This Privacy Notice explains how we collect, use, store, share, and protect personal data when you interact with Maltina, including through the Maltina Nourishment Tour, activations, competitions, surveys, nominations, and events.

    Please read this Privacy Policy carefully as it contains important information to help you understand our practices regarding any personal information that you give to us or that we collect otherwise in the context of the Website (“Personal Data”).

    Personal Data Collection and Use

    You may access most parts of the Maltina website without providing personal data. However, certain services, activities, or programmes require personal data in order for us to provide the relevant service or enable participation. Fields marked with an asterisk (*) are mandatory.

    If you do not provide the requested information, we will not be able to deliver the service or product to you or you cannot participate in the activity. In addition to the information you are required to provide to us in order to participate in activities/campaigns, we collect certain information when you visit our Website.

    A. General Nature of Information Collected

    We may collect personal data when you;

    • Nominate a school for the Maltina Nourishment Tour;
    • Participate in Maltina events, activations, or competitions;
    • Complete surveys (including pre- and post-tour surveys);
    • Contact us through forms, email, or social media;
    • Register for updates or communications.

    B. Information when you contact us

    If you visit our website and have a question or other remark, you can submit our Contact Form. You will be asked to provide your name and email address and obviously, information about your request. We will only use this information to respond to your question. We will register your requests, questions, and our responses, and other actions to handle your request.

    C. Information about your visit to and use of our website

    We collect certain information when you visit our website, such as your IP address, which web pages you visit, device category, browser, and type of internet browser, clicks, and views. We use this Personal Data as it is necessary in our legitimate interests to do so to be able to promote our products and services to our consumers and website visitors, to enable us to attract more consumers, and to improve the sale of our products and services.

    D. Information collected during Nourishment Tour

    During school visits and activations, we may collect:

    • Participation metrics (e.g. number of students, gender split)
    • Verification and assessment data
    • Facilitator attendance and performance feedback
    • Teacher and school representative comments
    • Event photographs and video footage

    Such data is collected strictly for programme administration, impact measurement, reporting, and safety purposes.

    E. Marketing

    If you subscribe, we will send you newsletters. You can always opt-out of receiving our newsletter and you can always object to our use of your Personal Data for direct marketing purposes. We use this Personal Data with your consent. We will delete your Personal Data when you opt-out of receiving our newsletter.

    F. Maintenance and optimisation of our website

    Your Personal Data will also be used for maintenance and analysis of our website to solve performance issues, to improve the availability and user experience. We log all use of our Website.

    G. NB events, competitions, activations, and other similar activities

    We may collect videos/images, photographs, social handles, drawings/sketches, and other similar or related personal information in line with the terms and purposes of such events, competitions, activations and similar activities.

    Our use of your Personal Data for these purposes is necessary in our legitimate interests and the information will be retained for as long as is legally permissible.

    Basis for Processing

    We process your Personal Data based on the following legal bases:

    • Consent: For participation in competitions, surveys, voluntary programmes, marketing communications, the use of images or recordings when requires and the use of cookies (where required).
    • Contractual necessity: To register participants, facilitate events, activations or prize fulfilment.
    • Legal obligations: To comply with applicable laws, regulations, lawful requests or legal processes.
    • Legitimate interests: To improve our website, understand user preferences, and promote our services, provided that such interests do not override your rights and freedoms.

    Data Sharing

    We may share personal data as follows:

    • Heineken Group Companies Data may be shared with other companies in the Heineken group for technical support, storage, shared IT system and responding to inquiries.
    • Service Providers and Data Processors Trusted third-party vendors to assist with analytics, event and tour operations, school verification, marketing, communication, and IT infrastructure and support. We ensure that such third-party vendors handle your data properly under contractual obligations.
    • Legal Obligations and Transactions Personal data may be shared as necessary for compliance with legal obligations, court orders, regulatory requirements or in cases where NB’s assets or shares are transferred.

    Transfers of personal data outside Nigeria will be subject to appropriate protections, and service providers are contractually required to maintain data confidentiality and security.

    Data Security and Retention

    We take technical and organizational measures to protect personal data and process it only for the minimum duration necessary. Once data is no longer needed, we securely destroy or de-identify it. We retain your Personal Data as follows:

    • Marketing Purposes For 6 years or until you withdraw your consent or opt out of communications.
    • Contractual Purposes For the duration of the contract and up to 6 years after its termination for legal or audit purposes.
    • Programme/Event Data For 6 years
    • Legal Compliance As required by law or for as long as necessary to demonstrate compliance.

    After these periods, we will securely delete or anonymize your data.

    Cookies

    We use cookies and similar technologies to support website functionality, analytics, and advertising. Non-essential cookies are used only with your explicit consent. You may manage cookie preferences through your browser settings or our cookie management tool.

    Social Media

    You may choose to share information on our website via third party social media platforms, such as Facebook, Instagram, LinkedIn, and YouTube. The processing of your personal data will be governed by those platforms’ privacy policies. NB is not responsible for their data practices.

    Children’s Privacy

    The Maltina website is not intended for direct use by children. Where activities involve minors:

    • Personal data is provided by parents, teachers, or authorised adults.
    • Data is used strictly for programme, educational, and reporting purposes.
    • Appropriate safeguards are applied in line with applicable law.

    Your Rights to Access, Rectification, Deletion, Restriction, and Data Portability

    NB Plc collects Personal Data only for the purposes identified in this Policy and such information cannot be reused for another purpose that is incompatible with the original purpose. This Policy describes your privacy rights regarding our collection, use, storage, sharing and protection of your personal information. You may exercise any of the following rights with respect to your Personal Data with NB Plc:

    You have the right to:

    • •Request for and access your personal data collected and stored by NB Plc
    • •Object to automated decision making
    • •Request rectification and modification of personal data
    • •Request for deletion or restriction of your personal data
    • •Provide consent prior to processing for other purposes
    • •Request that NB plc restricts processing
    • •Request information regarding specific processing

    You can exercise this right by contacting us with a data privacy request. Please note that requests that do not meet the requirements set out by applicable law or NB’s data protection policy may be requested to be re-issued or ultimately denied.

    You have the right to receive the Personal Data that you have provided to us in a structured, commonly used, and machine-readable format.

    Right to Object

    You also have a right to require us to stop processing your Personal Data, but where we have compelling legitimate grounds, we will continue processing your Personal Data. You may object to certain processing activities, including for direct marketing, and withdraw consent for processing where applicable.

    Security Measures

    We implement robust security measures, including encryption, access controls, and regular security audits, to protect your Personal Data against unauthorized access, loss, or misuse. Our measures are reviewed and updated regularly to align with the requirements of the Nigerian Data Protection Act and industry standards.

    Updates

    We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements, with updates posted on our website or to the extent reasonably possible, will be communicated to you. We encourage you to review this Privacy Policy regularly for any changes.

    Contact Us

    For any questions, concerns, or requests regarding this Privacy Policy, your rights or our data protection/privacy practices, please contact our Data Protection Officer:

    Email

    privacy.nbplc@heineken.com

    Postal Address

    Nigerian Breweries Plc, Iganmu House,
    No. 1 Abebe Village Road,
    Iganmu, Lagos, Nigeria.

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