United Breweries Limited (“UBL/we/us/our”) understands your concern for the privacy of your personal data and values the trust you place in us regarding its careful use. This Privacy Policy (also “Privacy Notice/Notice/Policy”) is designed to provide you with insights into the types of personal data we collect, the reasons behind its collection, and how we handle it. It is applicable to most of the activities carried out by UBL. We encourage you to acquaint yourself with our privacy practices and reach out to us via email at privacyoffice@ubmail.com if you have any questions. Learn more about your rights and how to exercise them by referring to the provided information here.

WHO IS COLLECTING?

UBL, where serving as the data fiduciary, oversees any personal data provided to or gathered by UBL. This Privacy Notice pertains to the personal data collected by UBL in relation to our website visits, office visits, the services and products we provide, or avail from you in case you are our vendor, supplier or business partner.

Furthermore, this Privacy Notice may extend to UBL's marketing content, encompassing offers and advertisements for UBL products and services which are permissible by law. We may reach out to you in this regard either directly or based on your usage of third-party platforms/websites which enable us to reach out to you in this regard. It's important to note that these third-party websites typically have their own privacy notice and terms & conditions, and we encourage you to review them before utilizing those platforms. Additionally, when collecting and processing personal data for a specific purpose where additional consent is necessary, we shall ask for the same from you and only then proceed with such collection and processing.

Personal data refers to any information that can be utilized to identify a specific individual, either directly or indirectly. While providing the personal data that UBL requests is optional, choosing not to do so may impact our ability to furnish you with our products or services, maintain a high standard of service, or address any inquiries you may have. This Policy may also be referred in certain cases where you provide your personal data to us voluntarily for a specified purpose and in respect of which you have not indicated to us that you do not consent to the use of your personal data.

WHAT PERSONAL DATA IS BEING COLLECTED BY US?

We gather personal data through various channels, including:

• Information you directly provide to us.
• Data collected automatically when you visit our website or other digital platforms.
• Information collected through third party platforms.

This definition encompasses personal data acquired offline and later digitized via customer and consumer engagement, permissible marketing campaigns, sweepstakes, competitions, as well as online through our websites, applications, and branded pages on third-party platforms and applications accessed through those platforms.

When you engage with us, you might be required to share personal data. United Breweries Limited may share this data internally and with other UBL Group companies, utilizing it in accordance with this Privacy Notice. Additionally, we may combine your data with other information to enhance our products, services and content, or otherwise to streamline the process of obtaining the products or services offered by you to us for carrying out our business activities.

It's important to reiterate that while providing requested personal data is not mandatory, choosing not to do so may impact our ability to provide you with our products or services or avail the services and products offered by you, maintain a high level of service, or address your queries effectively.

WAYS IN WHICH WE COLLECT YOUR PERSONAL DATA

We gather personal data from diverse sources, including:

Personal data you provide directly: We collect information about your usage of our services and products, such as the content you view or engage with, frequency and duration of your activities, and nature of services and products availed by you. When you sign up to complete a survey, or register an account, we may request personal data, including but not limited to your name, gender, date of birth, address, email address, telephone number, or the means through which you provide the consideration for our products and services or vice-versa.

Personal data collected automatically: When you interact with us online, we may receive and store certain types of personal/non personal data. This includes information obtained through cookies which are used when your web browser accesses our websites or when you interact with advertisements and content served by or on behalf of UBL on other websites. Examples of automatically collected personal data include:

• IP address, Cookies & Page views
• Login details, demographics & device type
• Traffic & usage trends on the website
• Operating System, browser type, clickstream data.
• Device ID, location data, browser type and version, time stamp of visit, purchase history etc.

Additionally, we may use software tools during your internet browsing on UBL’s websites to measure session information, download errors, and page interaction details. Technical information may also be collected for fraud prevention and diagnostic purposes. Purpose of collection of this data is to personalise user experience & web optimization. Most importantly, we may collect your age details either by requesting your date of birth, or by raising a request to confirm your age being above the legal drinking age as prescribed by applicable regulations in your relevant jurisdiction. This we do to ensure there is no non-compliance with excise and other laws on the subject matter.

Personal data obtained from other sources: We collect personal data from trusted partnerships with third parties and through UBL accounts on third-party platforms. For instance, interactions with our content on platforms like Facebook or Instagram may provide us with information. We receive data about your interactions with our content to assess its relevance and effectiveness. Furthermore, when jointly offering services or products with third parties or through data enrichment providers, we may obtain insights about the personal data we hold.

These data collection practices are outlined to provide transparency about how we handle and utilize personal information.

ADDITIONAL SAFEGUARDS FOR CHILDREN’S PRIVACY

While the majority of UBL’s websites are designed for adults due to the nature of our business activities, in cases where a website is intended for use by a younger audience, we will seek consent from the person with parental responsibility, as required by applicable laws and regulations. The age at which consent is necessary may vary from country to country as well as state wise. However, we will primarily give due regard to Indian data privacy regulations when processing any children’s data.

If you are a child below the age where parental consent is required in your country, it is recommended that you review the terms of this Privacy Notice with your parent or guardian to ensure comprehension and acceptance. In instances where we inadvertently collect personal data from a child without the required parental or guardian consent, we will promptly delete such information.

Access to specific sections of UBL’s websites and eligibility for certain benefits, such as prizes or rewards, is generally restricted to users above a specified age. To enforce age restrictions, we may use your personal data for age verification checks. Our commitment is to create a safe and secure online environment for users of all ages, especially children, and we actively work to comply with applicable regulations and uphold the highest standards of privacy protection.

PURPOSE OF USAGE

We collect, process, and disclose your personal data for specific and limited purposes, including but not limited to:

Processing Payments and Handling Inquiries:

• To process payments to our suppliers, customers and business partners to address inquiries and requests.
• To assess and handle complaints related to our products or services.

Product Development and Improvement:

To develop and enhance our products, services, communication methods, and website functionality.

Personalization:

Creating profiles based on analysis of your online surfing, searching, buying behaviour, and interactions with our brand communications.

Safety and Security:

If you visit our office or any other property, we may have installed tools to monitor your movement such as entry and exit time, places you visit etc. This we do to ensure that we can ensure your safety and security at all times when you visit our premises. We may retain a copy of such data for reasonable period in order to detect any offence and have supporting data to substantiate any allegation of violation.

When you apply to work with us:

We constantly endeavour to have the optimum human resources work with us and when you apply for any of the positions at UBL, we may ask you for relevant details in order to verify your identity, understand your qualifications, perform a due diligence etc.

Automated Decision Making:

Processing personal data using automated means for decision-making, where no human involvement occurs.

Competitions, Promotions, and Communications:

For competitions or promotions you participate in. To communicate information, manage registrations, and handle subscriptions to our sponsored events or other communications.

Business Operations:

• Managing everyday business needs related to your participation in contests, sweepstakes, promotional activities, or requests.
• Authenticating the identity of individuals contacting us by various means.
• Performing KYC checks, due diligence, fraud detection, ensuring validity of transactions and payments.

Internal Training and Quality Assurance:

For internal training and quality assurance purposes.

Consumer Insights and Development:

To understand and assess consumer interests, preferences, and changing needs. Improving our website, existing products, and services, and developing new ones.

In certain cases, we may rely on your consent for processing activities, and you have the right to withdraw your consent at any time. Additionally, we may process personal data based on certain legitimate uses, ensuring that such processing is necessary and does not outweigh your individual rights. We keep a record of such instances, and you have the right to request this information.

Furthermore, we process your personal data to fulfil contractual obligations (e.g., delivering and receiving products or services) and comply with legal obligations (e.g., tax or other statutory requirements). This requires us to follow the applicable regulatory KYC norms and collect and process KYC related information to sustain our business relationship with you.

SHARING OF PERSONAL DATA

UBL may shares your personal data within its Group companies and with selected third parties under the following circumstances:

Third-Party Service Providers:

Your personal data is shared with third-party service providers to fulfill your requests, respond to inquiries, process payments, verifying transactions, scrutinizing for potential contractual violations or violations of law, provide customer service. Additionally we may use third party processors to perform functions on UBL's behalf in line with the purpose with which you have shared such data with us.

These service providers, such as website hosts, payment processors, auditors and related services, have access to necessary personal data but are restricted from using it for other purposes. They are required to process the data in compliance with the purpose you have shared your data with us and applicable data protection laws. Wherever required, we enter into valid agreements with third party processors to safeguard your rights as a principal.

Other Third-Parties:

Your personal data may be used or shared with sponsors, advertisers, advertising networks, social media networks, analytics companies, and other third-parties for data enrichment purposes.

Business Transfers:

• Personal data is used or shared within UBL Group companies for business and operational purposes.
• In the event of asset sales, acquisitions, or business unit transactions, your personal data may be transferred as one of the business assets. The data remains subject to the promises made in any pre-existing Privacy Notice unless you provide consent otherwise.

Legal Disclosures:

Your personal data may be transferred and disclosed to third parties. At times, it becomes necessary to process personal data either ourselves or through a third party to fulfil our obligations under the prevailing laws in India. This includes enforcing legal rights or claims. Additionally, in the interest of preventing, detecting, investigating, or prosecuting any offense or violation of current laws in force in India, processing personal data may be required. These measures are implemented to ensure compliance and uphold the legal framework within the country.

• To verify or enforce the "Terms of Use" or other relevant policies.
• To detect and protect against fraud, technical or security vulnerabilities./li>
• In response to emergencies or to protect the rights, property, safety, or security of third-parties, visitors to UBL's websites, UBL, or the public.
• These disclosures are made in adherence to legal requirements and aim to protect the interests and security of individuals and the wider community.

INTERNATIONAL DATA TRANSFER

UBL may share personal data within the UBL Group or with third parties for the purposes outlined in this Privacy Notice. Personal data collected within specific legal frameworks, like the European Economic Area (EEA) will only be transferred to countries having data protection laws that offer equivalent levels of protection in situations such as:

• Following your instructions
• Complying with legal obligations, or/li>
• Collaborating with our agents and advisers assisting in our business operations and services.

If personal data is transferred outside of these legal frameworks, UBL ensures it is safeguarded to the same standards. This can be achieved by:

• Transferring it to a country with privacy legislation ensuring a level of protection similar to the one it was collected in, or
• Establishing a contract with the third party, obligating them to uphold personal data protection standards equivalent to those in the country where the data was collected.li>
• We never share your data outside the country in case where appropriate government in India has restricted the transfer of personal data by a data fiduciary for processing to such country or territory outside India.

HOW WE PROTECT YOUR PERSONAL DATA?

UBL places a high priority on ensuring the security of your personal data. We are committed to taking all necessary measures to prevent its misuse, interference, loss, unauthorized access, modification, or disclosure. We will take appropriate technical and organizational measures that are consistent with applicable privacy and data security laws and regulations to protect the personal data collected through the Website. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.

Other websites may contain links to our website and vice-versa. We are not responsible for the privacy practices, content or security used by such other websites, which shall not be governed by this Privacy Policy. We advise you to always read the privacy policies carefully on these other websites.

Access to your personal data is strictly limited to our employees and agents on a need-to-know basis. When third parties are involved in processing your data, they are bound by contractual confidentiality obligations to maintain adequate standards of data security and data processing.

DATA RETENTION

We will retain your Personal Data for as long as legally required or for as long as necessary to provide you with any requested services or for any of the other purposes listed in this Privacy Policy. We will take reasonable steps to delete or de-identify your Personal Data we hold when it is reasonable to assume that the specified purpose is no longer being served and we will do so as soon as it is reasonably practical to destroy or de-identify such Personal Data. For instance, if you supply us certain goods or services, we will keep the relevant data associated with your supply and relevant to execute the specific contract you've entered. Subsequently, we will retain the personal data for a period that allows us to address any complaints, queries, or concerns related to the purchase or retention is prescribed by law/ retention is necessary according to the law of limitation dealing with the subject matter in raising and defending a dispute.

Your data may also be preserved to enhance your overall experience with us. Identifiable data collected for targeting purposes is kept for the shortest possible time, following which we implement measures to permanently delete it.

We consistently review the personal data in our possession and securely delete or, in some cases, anonymize it when there is no longer a legal, business, or consumer necessity for its retention. This proactive approach ensures that we maintain the highest standards of data management and protection.

If consent is the basis for processing of your personal data and you choose to withdraw your consent for such processing, we will within a reasonable time, cease and cause our third party processors, if any, to cease processing of your personal data unless such processing without your consent is required or authorised under the applicable Data Privacy laws or any other law for the time being in force in India.

You shall at all times have the right to correction, completion and updating your personal data and upon receiving a request from you we shall as soon as reasonably practicable, fulfil your request in this regard.

HOW TO CONTACT US?

We are dedicated to safeguarding your personal information, and we appreciate your ongoing support in this regard. If you have any questions or concerns about the processing of your information by us, please feel free to contact us.

You can reach us by emailing at: privacyoffice@ubmail.com

For further assistance or in the event of unresolved grievances, you can contact our Privacy Office.

Reach out to our Privacy Officer at: Privacy Officer, United Breweries Limited, UB Tower, UB City, #24, Vittal Mallya Road, Bengaluru – 560001

Upon receiving privacy-related inquiries or access requests, our dedicated team promptly addresses the specific concerns or queries you raise. If the matter is more substantive, additional information may be requested from you. If you find our response unsatisfactory, you have the option to escalate your complaint to the relevant supervisory authority. We are here to assist you and will provide information about applicable complaint avenues upon request.

ADDITIONAL NOTICES WHEN RELEVANT

In addition to this Privacy Notice, there may be specific campaigns or promotions which will be governed by additional privacy terms or notices. We encourage you to read these additional terms or notices before participating in any such campaigns or promotions as you will be required to comply with them if you participate. Any additional privacy terms or notices will be made prominently available to you.