ASAHI GROUP
Privacy Policy for EEA Personal Data (For Customers and the like)
This Privacy Policy applies to the corporate group made up of Asahi Group Holdings, Ltd.,
with its headquarters located at 23-1, Azumabashi 1-chome, Sumida-ku, Tokyo, 130-8602,
Japan (“AGH”), and its subsidiary companies located in Japan (the “Group Companies,”
and the corporate group, the “Asahi Group”. Each company of the Asahi Group is referred
to as an “Asahi Group Company”.).
Please read this Privacy Policy carefully to understand how the Personal Data ofdata subjects is handled.
This Privacy Policy applies to any of the following instances of processing of Personal Data
related to any Asahi Group Company’s customers, business partners (and the staff
members, shareholders, and website users of those business partners), or consumers:
(i)
(ii)

handling of Personal Data in connection with the activities of establishments locatedin the EU, regardless of whether that handling is conducted in or outside the EU; andhandling by a Group Company not established in the EU of the Personal Data of data
subjects the EU; provided, however that such handling activities are limited to thosein connection with the following items:(a) handling related to the provision of goods or services to data subjects the EU,
regardless of whether payment of the data subject has been requested; or(b) handling related to the oversight of a data subject’s activities engaged in within
the EU.

In particular, data subjects are requested to take care when using the website of,contacting through social media, communicating with, entering or leaving the premises of,offering goods or services to, using any of the goods and services provided by, or otherwise
providing their own personal data to, any Asahi Group Company (including providing theirown Personal Data in order to enter competitions or to participate in events, such as
brewery tours).
In this Privacy Policy, EU refers to the following 27 member states of the European Union(subject to future fluctuations in the number of member states):
Belgium, Bulgaria, Czech Republic, Denmark, Germany, Estonia, Ireland, Greece, Spain,
France, Croatia, Italy, Cyprus, Latvia, Lithuania, Luxembourg, Hungary, Malta, The
Netherlands, Austria, Poland, Portugal, Romania, Slovenia, Slovakia, Finland, and Sweden;
provided, however, that the definition of EU in this Privacy Policy also includes the United
Kingdom, Iceland, Norway, and Liechtenstein.
In addition, in this Privacy Policy, the General Data Protection Regulation 2016 and thedata protection laws in the United Kingdom are collectively referred to as the European
Data Protection Laws.
Contents:
Section 1:

Acquisition of Personal Data

Section 2:

Use of Personal Data
1

Legal basis under the European Data Protection Laws for use
of Personal Data

(2)

Cookies(3)

Marketing

Section 3:

Disclosure of Personal Data

Section 4:

Retention of Personal Data

Section 5:

Rights of data subjects

Section 6:

Transfers of Personal Data

Section 7:

Security

Section 8:

Third party websites

Section 9:

Changes to Asahi Group’s Privacy Policy

Section 10:
1.

(1)

Further questions or making a complaint

Acquisition of Personal Data
Some data about a data subject may be acquired directly from that data subject.
However, data about a data subject may also be acquired from any corporations ororganizations with whom the data subject is affiliated (“Affiliated Parties”) or fromany other third parties such as vendors from whom the data subject has purchased
goods, market research companies, websites, advertising agencies (including talent
agents), and public agencies ("Third Parties"). Depending on context, the Third
Parties may include AGH’s subsidiary companies located outside Japan, etc.
Each Asahi Group Company and any subcontractors of that Asahi Group Company
may acquire and use any of the following data about a data subject (“Personal
Data”):

1.1

Acquisition methods and types of Personal Data
The Personal Data which a data subject or any of a data subject’s Affiliated Parties
provides to an Asahi Group Company (or which an Asahi Group Company acquires
from a Third Party) may include the following:(a)

If a data subject contacts an Asahi Group Company (through use of an online
form, completing an order form, setting up an account, or by phone, e-mailor other means):
(i)

name;

(ii)

job title;(iii)

names of Affiliated Parties;(iv)

e-mail address;(v)

telephone number;(vi)

records of telephone calls;(vii)

account information;(viii)

addresses of Affiliated Parties;(ix)

gender;(x)

date of birth/age; and

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(xi)

(b)

(c)

profile data from social media (including data subject’s preferences
and correspondence).

If a data subject visits the premises of an Asahi Group Company orparticipates in an event such as a brewery tour:
(i)

name;

(ii)

job title;(iii)

names of Affiliated Parties;(iv)

e-mail address;(v)

telephone number;(vi)

addresses of Affiliated Parties;(vii)

gender;(viii)

date of birth/age; and(ix)

images of the data subject recorded by CCTV cameras.

If a data subject uses websites or software apps of an Asahi Group Company:
(i)

name;

(ii)

user name;(iii)

date of birth/age;(iv)

website viewing history (for example, the pages that the data subject
clicks on);(v)

payment details;(vi)order history; and(vii)

the following data that is automatically acquired:▪

technical data (including the IP address used to connect thedata subject’s device to the internet, the domain name used
and the country from where the data was requested, files,
browser type and version, browser plug-in types and versions,and operating system and platform);▪

data related to website visits (including the URL clickstream
to, through, and from the website of an Asahi Group Company(including date and time), dates, times, and lengths of visits
to certain pages, page interaction data (including scrolling,clicks, and cursor hovers), methods used to browse away froma page, traffic data, location data, web logs and othercommunication data, and data provided when a customer
requests provision of services or downloads); and▪

in the case of a mobile application, necessary location
information and, if the data subject is a service provider,location information so that the effectiveness and efficiency of
any services provided by that data subject to an Asahi Group
Company can be monitored.

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(d)

(e)

If an Asahi Group Company provides a data subject with goods or services:(i)

data needed to provide goods or services to the data subject (refers
to data such as account information, details of orders, order history,
payment details, delivery address, bank accounts, delivery
requirements and restrictions, and includes trade references and tax
information);(ii)

the name given by the data subject to an Asahi Group Company for
personalised products;(iii)

details of services provided to the data subject;(iv)

existence of any litigation proceedings, trial proceedings, ADR or
investigation proceedings and summaries thereof;(v)

data related to customer relationship management and marketing
conducted by the Asahi Group Company; and(vi)photos and videos of the data subject at the premises, events, or the
like of the Asahi Group Company.

If an Asahi Group Company receives goods or services from a data subject
or any of that data subject’s Affiliated Parties (including manufacturingsubcontractors, suppliers, advertising agencies, transport suppliers,
warehouses, system providers and engineers, advertising spokespersons
and other contractors):(i)

websites of data subjects who are sole proprietors;(ii)

photo and video footage if the data subject is an advertisingspokesperson (including if the data subject is a potential advertisingspokesperson);(iii)

records of telephone calls;(iv)

work history, etc. of the data subject recorded on CVs, sales
materials, sales proposal materials and the like;(v)

supplier due diligence results, etc.;(vi)

work contact details (phone number, address, e-mail address);(vii)

proof of identification, certificate of residence, etc.;(viii)

passport, visa, etc.;(ix)

emergency contacts;(x)

results of health examinations, etc. and details of illnesses or injuriescaused by industrial accidents;(xi)

work hours (overtime hours, hours worked, and standard work hoursof Affiliated Parties) and whether there is shift work;(xii)

compensation, expense claims, and payee details for compensationand expense claims;(xiii)

results of clinical trials (drug and alcohol testing, etc.);(xiv)

existence of any litigation proceedings, trial proceedings, ADR or
investigation proceedings and summaries thereof; and

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(xv)

data required to access systems and applications of Affiliated Parties(such as system IDs).

Some of the Personal Data that an Asahi Group Company acquires or of which an
Asahi Group Company receives provision may include special categories of Personal
Data. Special categories of Personal Data include data about the physical andmental health of the data subject.
Please understand that certain types of Personal Data are required so that Asahi
Group Companies can provide services to data subjects or so that data subjects canprovide services to Asahi Group Companies. If a data subject does not provide such
Personal Data, or if a data subject requests an Asahi Group Company to delete such
Personal Data, that data subject may no longer be able to receive goods andservices from, or provide goods and services to, any Asahi Group Company.
If a data subject is a journalist or works for an administrative institution/tradeassociation in the industry of any Asahi Group Company, the relevant Asahi Group
Company may collect data about the data subject from public information.
2.

Use of Personal Data

An Asahi Group Company or any subcontractor thereof may use any of the Personal Datalisted above for any of the following purposes:
2.1

2.2

If a data subject contacts an Asahi Group Company:(a)responding to enquiries from the data subject (including questions regarding
the manner in which the Asahi Group Company acquires, uses, and stores
Personal Data, and requests for copies of the Personal Data retained by the
Asahi Group Company);(b)reporting within the Asahi Group; and(c)social media research for the advertisement, promotion, and developmentof goods, where it is in the legitimate interests of the Asahi Group Company.

If a data subject visits the premises of an Asahi Group Company or participates inan event such as a brewery tour:
(a)

2.3

ensuring the safety of staff members of the Asahi Group Company and of its
visitors through monitoring by CCTV cameras.

If a data subject uses any website or software app of an Asahi Group Company:(a)to allow the data subject to access and use the website or the app (including
to ensure that the data subject is of the legal drinking age provided under
the laws and regulations of each applicable country and/or region);(b)

to provide technical support for websites or apps;(c)to provide the data subject with the information and services that it
requests;(d)to ensure the security of the services, websites, and apps of the Asahi Group
Company;

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2.4

2.5

(e)

to customise websites and apps according to the data subject’s preferences
and interests;(f)to manage the usage status of the Asahi Group Company’s websites;(g)to enable the functions of apps (including apps that present bars locatednearby), to carry out market research on beer consumption, preferences,and the like at bars in which the app was used;(h)to manage participants in the Asahi Group Company’s competitions andpromotions;(i)to process orders for goods or services provided by the Asahi Group
Company; and(j)to conduct analysis for development of and updates to websites and apps of
the Asahi Group Company and for the development of goods and services
by the Asahi Group Company, and to formulate strategies based on thatanalysis.

If receiving goods or services from a data subject or its Affiliated Parties:(a)to acquire and manage services from the data subject (management
includes supplier due diligence, payment and expense reporting and financial
audits);(b)

for payment of consideration, etc. to the data subject;(c)

for recording and managing the health and safety of the data subject;(d)to assess the working capacity of the data subject (for example, to assess
whether the data subject is under the influence of drugs or alcohol, thereby
posing a danger to the data subject himself/herself and to others); and(e)to confirm information on CVs and to conduct performance reference checks
in order to assess the suitability of the data subject or the data subject’s
employer; and(f)for equal opportunities monitoring.

If providing goods or services to a data subject:(a)to manage the goods and services provided to the data subject (including toconfirm and process orders, to manage the data subject’s accountinformation, to manage credit information, administrative processing of tax
and exports, billing details, debt collection, and the collection of bottles);(b)

to deal with any enquiries from the data subject about the goods or servicesof the Asahi Group Company, including any questions from the data subject
about how Personal Data is acquired, used, and stored, or any requests
made by the data subject for a copy of the data held by the Asahi Group
Company about the data subject. If the Asahi Group Company does not havea contract with the data subject, that company may process the data
subject’s Personal Data for these purposes where it is in that company’s
legitimate interests for customer services purposes;(c)to send communications (including by e-mail or post) about the goods andservices of the Asahi Group Company, such as service announcements andnotices (for example, setting out changes to the terms and conditions of the6Asahi Group Company and keeping the data subject informed about the fees
and charges of the Asahi Group Company);(d)to allow the data subject to attend events or participate in competitions run
by the Asahi Group Company and to send the data subject photos taken ofthat data subject with that data subject’s permission;(e)for health and safety and quality assurance;(f)

to carry out statistical analysis and market research; and(g)

if the data subject has consented or if it is in the legitimate interests of the
Asahi Group Company for business development and marketing purposes,
to provide the data subject with information or the like about the goods andservices of the Asahi Group Company which either the data subject requests
or which the Asahi Group Company feels will be of interest to the data
subject (including newsletters, but limited to only those goods or services towhich the data subject has consented.)

2.6

If an Asahi Group Company uses photos or video footage of a data subject from an
event, in order to promote future events or to conduct internal presentations at any
Asahi Group Company, where it is in the legitimate interests of that Asahi Group
Company for marketing or business development purposes or where the data
subject has given consent.

2.7

For internal corporate reporting within the Asahi Group, business administration,
insuring the business and facilities of an Asahi Group Company, and to carry out
research and measures in order to enhance research and development andproductivity.

2.8

To comply with applicable laws and regulations or with any internal rules which
apply to an Asahi Group Company – this may include where it is reasonably
considered that such compliance is in the legitimate interests of an Asahi Group
Company or of a Third Party.

2.9

To establish, exercise or defend the legal rights of an Asahi Group Company – thismay include where it is reasonably considered that this is in the legitimate interestsof an Asahi Group Company or of a Third Party, or where it is required to do sounder applicable laws and regulations.

2.10

If providing a data subject who is a journalist with information with the aim ofhaving that data subject write a news article about the goods and services of an
Asahi Group Company is in the legitimate interests of an Asahi Group Company, toinvite that data subject to events and to send that data subject promotional material
and to issue press releases.
(1)
Legal basis under the European Data Protection Laws for use of
Personal Data

2.11

Each Asahi Group Company considers that the legal bases for using your Personal
Data as set out in this Privacy Policy are as follows:(a)for an Asahi Group Company to perform its obligations under any contract
with a data subject (for example, to fulfil an order placed by a data subject,to provide a data subject with services through that data subject’s use of
any website or software app of an Asahi Group Company, and/or to comply
with a contract to provide services to, or acquire services from, a data
subject or the employer of a data subject);

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2.12

(b)

for an Asahi Group Company to comply with its legal obligations underapplicable EU laws or the applicable laws of each EU country (for example,
providing information to HMRC); or(c)where neither (a) nor (b) apply, for the legitimate interests of an Asahi
Group Company or of a Third Party (for example, to ensure the security of
the websites or software apps of an Asahi Group Company). The legitimate
interests of each Asahi Group Company are:(i)to run, grow and develop the business of the Asahi Group Company;(ii)

to operate the websites and software apps of the Asahi Group
Company;(iii)

to select suppliers;(iv)

to ensure a safe environment for the staff members of the Asahi
Group Company and for visitors to the premises of, and participantsin events held by, the Asahi Group Company;(v)

marketing, market research and business development;(vi)

to provide goods and services to customers and to confirm theidentity of a data subject during payment;(vii)

to place, track and ensure fulfilment of orders with suppliers of the
Asahi Group Company; and(viii)

for internal administrative purposes within the Asahi Group, as
described in paragraph 3.1 below.

Each Asahi Group Company may use special categories of the Personal Data of adata subject where that data subject has provided its consent (which that data
subject may withdraw at any time after giving it, as described below).
In the future, the use of Personal Data for other purposes may be subject to consent
of the data subject (which can be withdrawn at any time after giving it, as described
below). Where this is the case, that need for consent will be identified in this Privacy
Policy.
(2)

Cookies

2.13

Some pages on the websites and mobile apps of each Asahi Group Company use
cookies, which are small files placed on the internet browser of the data subject
when that data subject visits a website or uses an app of an Asahi Group Company.
Each Asahi Group Company uses cookies in order to offer data subjects a more
tailored experience in the future, by understanding and remembering the data
subject’s particular browsing preferences.

2.14

Where an Asahi Group Company uses cookies on its websites or mobile apps, a data
subject may block these at any time. To do so, the data subject can activate thesetting on its browser that allows the data subject to refuse the setting of all orsome cookies. However, if a data subject uses the browser settings to block all
cookies (including essential cookies), that data subject may not be able to accessall or parts of the websites of each Asahi Group Company or be able to use all of
the functionality provided through the websites of each Asahi Group Company.

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(3)

Marketing

2.15

Each Asahi Group Company may collect and use the Personal Data of a data subject
in order to conduct marketing by e-mail, app, phone, or post.

2.16

Each Asahi Group Company may, if it considers it necessary for marketing purposes,
send to a data subject certain marketing materials (including direct marketing).

2.17

However, if it is required under the European Data Protection Laws or the laws ofeach EU country, or if an Asahi Group Company plans to disclose to a Third Party
the Personal Data of a data subject for direct marketing purposes, that Asahi Group
Company will always obtain the data subject’s consent to direct marketing.

2.18

If a data subject desires that use of its Personal Data for marketing purposes be
stopped, that data subject is requested to contact the contact points for Asahi Group
Companies using the contact details set out in Section 10.2.

3.

Disclosure of Personal Data

3.1

Each Asahi Group Company may jointly use with any of AGH and/or another AGH’s
subsidiary company the Personal Data of a data subject, where it is in the legitimate
interests of those Asahi Group Companies to do so for internal administrative
purposes (for example, ensuring the stable provision of services to customers,
corporate strategy, compliance, auditing and monitoring, research anddevelopment and quality assurance). Each Asahi Group Company may also jointly
use the Personal Data of a data subject with those affiliated companies of the Asahi
Group to whom work related to such systems as information technology systems is
subcontracted.

3.2

Each Asahi Group Company may share the Personal Data of a data subject with anyof the following Third Parties:

3.3

(a)

service providers and subcontractors of the Asahi Group Company, including
but not limited to payment processors, suppliers of technical and support
services, insurers, logistic providers, and cloud service providers;(b)corporations or organizations with whom the data subject is affiliated;(c)

distributors and vendors;(d)public agencies;(e)occupational health assessment providers and medical professionals
undertaking drug and alcohol testing;(f)agencies for the marketing, advertising and promotional activities of the
Asahi Group Company; and(g)data analytics providers and search engine providers that assist in the
improvement and optimisation of the websites and software apps of the
Asahi Group Company.

Any Third Parties to whom the Personal Data of a data subject is provided are limited(by the European Data Protection Laws and the laws of each EU country, and bycontract) in their ability to use that Personal Data for any purpose other than toprovide services for an Asahi Group Company.
Each Asahi Group Company imposes on Third Parties an obligation to employ
appropriate measures related to privacy and security as set out in this Privacy
Policy, and in the European Data Protection Laws and the laws of each EU country.
93.4

Each Asahi Group Company will ensure that any Third Parties with whom it shares
the Personal Data of a data subject are subject to privacy and security obligations
consistent with this Privacy Policy, and the European Data Protection Laws and thelaws of each EU country. Each Asahi Group Company will also disclose the Personal
Data of a data subject to Third Parties:(a)where it is in the legitimate interests of the Asahi Group Company to do so
to run, grow and develop that company’s business. The following purposes
constitute legitimate interests:(i)

if an Asahi Group Company sells or buys certain business or assets,that company may disclose the Personal Data of a data subject to theprospective seller or buyer of such business or assets; or(ii)

if substantially all of the assets of an Asahi Group Company or any ofthat company’s affiliate companies happens to be acquired by a third
party, in which case the Personal Data held by that Asahi Group
Company will be one of the transferred assets to that third party;(b)

to comply with any lawful request from a national or local government,
administrative institution or judicial institution official and as may berequired to meet national security or law enforcement requirements or toprevent illegal activity;(c)when applying the terms and conditions for use of a website or the like ofan Asahi Group Company or when applying any other agreement, or to
respond to any claims made by a customer to an Asahi Group Company, toprotect the rights of an Asahi Group Company or the rights of a Third Party,
for safety, or to prevent any illegal activity; or(d)to protect the rights and property of the staff members of an Asahi Group
Company or of Third Parties. This may include exchanging Personal Datawith other organisations for the purposes of fraud protection and credit risk
reduction.

3.5

Each Asahi Group Company may disclose and use statistics information made up of
a combination of Personal Data acquired from its websites and apps, Personal Dataof data subjects to whom it provides goods or services, and Personal Data acquiredon social media, for the purposes of internal reporting within the Asahi Group,
marketing, and sales promotion. None of these anonymised, aggregated reports or
statistics will enable users of an Asahi Group Company to be personally identified.

3.6

Save as expressly detailed above, each Asahi Group Company will never share orprovide any Personal Data of a data subject to any Third Party without notifying therelevant data subject and, where necessary, obtaining the relevant data subject’s
consent. If a data subject has given its consent for an Asahi Group Company to usethat data subject’s Personal Data in a particular way, but that data subject laterchanges its mind, that data subject should contact the relevant Asahi Group
Company, and that company will stop doing so.

4.

Retention of Personal Data
Each Asahi Group Company keeps Personal Data for the length of time required tofulfil the purposes of use of that Personal Data, to comply with the applicable laws
and regulations of each country and/or region, and to establish, exercise or defend
that company’s legal rights and obligations.

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5.

Rights of data subjects

5.1

A data subject has certain rights in relation to its Personal Data that is retained by
any Asahi Group Company. If a data subject would like further information in
relation to such rights or would like to exercise any of those rights, that data subject
should contact the relevant Asahi Group Company by phone or e-mail. If it ispermitted under the European Data Protection Laws or under the laws of each EU
country, a data subject has the right to request that an Asahi Group Company:(a)provide that data subject with access to its Personal Data;(b)update any of that data subject’s Personal Data which is out of date orincorrect;(c)delete that data subject’s Personal Data;(d)restrict the way that it processes that data subject’s Personal Data;(e)not process that data subject’s Personal Data for direct marketing purposes;(f)provide, or not provide, that data subject’s Personal Data to a Third Party;(g)provide that data subject with a copy of any of its Personal Data; or(h)consider any valid objections which that data subject has to the use by an
Asahi Group Company of its Personal Data.

5.2

Each Asahi Group Company will consider all such requests and provide a response
within a reasonable period (and in any event any time period required by EU laws
or the laws of each EU country). Please note, however, that certain Personal Data
may be exempt from such requests in certain circumstances.

5.3

If an exception applies, the relevant Asahi Group Company will tell the data subject
this when responding to that data subject’s request. An Asahi Group Company may
request a data subject to provide information necessary to confirm that data
subject’s identity before responding to any requests that data subject makes.

5.4

If an Asahi Group Company cites a data subject’s consent as its reason for usingthat data subject’s Personal Data, that data subject may withdraw its consent by
contacting the relevant Asahi Group Company by phone or e-mail, and the relevant
Asahi Group Company will stop use of that Personal Data. However, if a data subject
withdraws its consent and that data subject is providing an Asahi Group Company
with services, that withdrawal of consent may impact the details of that data
subject’s services, and if an Asahi Group Company is providing that data subject
with services, such withdrawal of consent may also impact the details of the servicesof that Asahi Group Company.

6.

Transfers of Personal Data

6.1

Personal Data may be used, stored and/or accessed by staff members operating
outside the EU working for an Asahi Group Company or for any of its subcontractors.
As set out in Section 2 above, such processing is conducted for the provision ofservices by an Asahi Group Company to a data subject or any of its Affiliated Parties,
the acquisition of services from a data subject or any of its Affiliated Parties, theprocessing of transactions, and/or the provision of support services. Further details
on to whom a data subject’s Personal Data may be disclosed are set out in Section
3 above.

6.2

If an Asahi Group Company provides any Personal Data about a data subject to any
Third Party not established in the EU, that Asahi Group Company will takeappropriate measures to ensure that the recipient protects the data subject’s
11Personal Data adequately in accordance with this Privacy Policy. These measures
mainly include, but are not limited to, entering into approved standard contractual
arrangements with it.
6.3

If a data subject makes an enquiry to the contact points for Asahi Group Companies
as set out in Section 10.2, an Asahi Group Company will provide that data subject
with further details on the measures set out above.

7.

Security

7.1

Each Asahi Group Company is committed to protecting Personal Data from loss,
misuse, disclosure, alteration, unauthorised access, unavailability and destruction
and takes all reasonable precautions to safeguard the confidentiality of Personal
Data, including through appropriate organisational and technical measures.
Organisational measures include physical access controls to the premises of each
Asahi Group Company, staff member training and locking physical files in filingcabinets. Technical measures include such measures as the use of encryption,
passwords for access to the systems of each Asahi Group Company, and the use ofanti-virus software.

7.2

In the course of provision of a data subject’s Personal Data to an Asahi Group
Company, such Personal Data may be transmitted over the internet. Although each
Asahi Group Company makes every effort to protect the Personal Data provided bya data subject, the transmission of information over the internet is not completely
secure. As such, each data subject acknowledges and accepts that each Asahi Group
Company cannot guarantee the security of Personal Data transmitted to its websites
and that any such transmission is carried out at the data subject’s own risk. Oncean Asahi Group Company has received a data subject’s Personal Data, that company
will use strict procedures and security features to prevent unauthorised access to
it.

7.3

Where an Asahi Group Company has given a data subject (or where a data subject
has chosen) an ID and password which enables that data subject to access its online
account, that data subject is responsible for keeping the ID and password
confidential. Data subjects are asked not to share the ID and password with anyone.

8.

Third party websites
The websites, apps and social media pages of an Asahi Group Company may, fromtime to time, contain links to websites operated by third parties including theaffiliated companies of that Asahi Group Company. Please note that this Privacy
Policy only applies to the Personal Data that an Asahi Group Company or any of its
subcontractors acquires through the websites, apps and social media pages of Asahi
Group Companies, and no Asahi Group Company can be responsible for Personal
Data that is acquired, used, and/or stored by third parties. Third party websites
have their own terms and conditions and privacy policies, and data subjects should
read these carefully before submitting any Personal Data to these websites. Asahi
Group Companies do not endorse or otherwise accept any responsibility or liability
for the content of such third party websites or third party terms and conditions or
privacy policies.

9.

Changes to Asahi Group’s Privacy Policy
The Asahi Group may update its Privacy Policy from time to time. Any changes that
the Asahi Group makes to its Privacy Policy will be posted on this page.
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10.

Further questions or making a complaint

10.1

If a data subject has any queries or complaints about the acquisition, use or storageof its Personal Data, or if a data subject wishes to exercise any of its rights inrelation to its Personal Data, that data subject should contact the contact points set
out below. An Asahi Group Company will investigate and respond to any suchenquiry from a data subject regarding the use or disclosure of its Personal Data.

10.2

A data subject may also make a complaint to the data protection authority in the
EU country where the relevant Asahi Group Company is based or, in the case of adata subject in the EU to whom goods or services are provided, to the dataprotection authority in the EU country where personal data that relates to those
goods or services is processed. Also, a data subject may seek a remedy throughlocal courts if that data subject believes that its rights have been breached.
Contact details:
The contact details for Asahi Group Companies are as follows. You can make anenquiry to either (a) or (b) using the following details:(a)Contact details for the representative of those Asahi Group Companies
established within the Europe:
Name of representative:(b)

Asahi CE & Europe Services s.r.o.

Address:

Ovocný trh 1096/8, Staré Město, 110 00 Praha 1,
Czech Republic

Enquiries to (FAO):

Legal Director

E-mail address:

personaldataprotection@eu.asahibeer.com

Contact details for the customer service centres established in Japan:
Asahi Breweries, Ltd. Customer Service Centre
Address:
8602

23-1, Azumabashi 1-chome, Sumida-ku, Tokyo, 130-https://www.asahibeer.co.jp/webservice/asahibeer/customer/contact_us_e/form.wsp.html?CMD=onForm
10.3

The practices described in this Privacy Policy are the current personal dataprotection policies of Asahi Group Companies, as of April 1, 2023.

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