Information for users of 360 Learning, HEINEKEN’s global learning solution.
What does this Privacy Notice cover?
This Privacy Notice explains how your HEINEKEN operating company (“we” or “us”) collects, uses and manages the personal data of users of 360 Learning (“360 Learning”) (“you” or “your”) both via its website and UBrew mobile app. This notice informs you which personal data we process, how we process it, how long we will retain your personal data, how you can access and update your personal data and where to go for further information. For the purposes of this Privacy Notice, personal data means any information or set of information that directly or indirectly identifies you, such as your name, job details or email.
This Privacy Notice is specific to 360Learning and supplements the general employee privacy notice.
Which HEINEKEN entity is responsible for your personal data?
The local Heineken organization that you are employed by or that has otherwise engaged you, is the data controller for the processing of your personal data.
We are part of the HEINEKEN group of companies. HEINEKEN International B.V. is the main operating and management company within the group. Where the processing of personal data is undertaken for the own independent purposes of HEINEKEN International B.V., it will be a data controller in its own right and therefore responsible for your personal data. These include the execution of global HR processes, reporting, global insights and HR analytics, organisational analysis and development of the group and provision of global management information.
You can contact the Global Privacy Office at HEINEKEN International B.V. for further information and inquiries via our data privacy request form. Find more information about the work of the Global Privacy Office including contact details on the intranet.
We collect the following personal data which you provide or which is automatically collected:
Personal details:
Your name, email address, employment details such as job title and work location, operating company, line manager, hire date, country, cost centre, (sub-)function, start date, last day of employment, employee type, line manager and line manager email address.
Purpose: Assigning relevant learning content
Lawful basis: Legitimate interest – it is in our and your interest to offer learning and development opportunities. It is also necessary for the performance of the employment agreement to complete mandatory courses.
Account management details:
Log-in details, HEIWay account data, employee ID / user ID
Purpose: Account management
Lawful basis: Legitimate interest – it is in our and your interests to ensure your continued access to 360 Learning
Training and usage data:
Language preference, training history, completion and scores, statistics such as duration of the training
Purpose: Reporting purposes, measuring and analysing the completion rate of courses and resolving user issues.
Lawful basis: Legitimate interest – it is in our interest to offer learning and development opportunities. In some cases local law may require us to retain records of completed mandatory courses.
Your content:
Audio information, prompts to the AI content generator (only for specific types of users) and all data that you publish and upload on 360Learning, including the forum and chat.
Purpose: Online learning and training, to facilitate communication and questions.
Lawful basis: Legitimate interest – it is in our and your interest to offer learning and development opportunities.
Your personal data can be shared within and outside of the HEINEKEN group of companies. Any personal data shared with third parties is limited to what they need to perform their designated functions and third parties are obligated not to disclose or use it for any other purposes.
Service providers:
HEINEKEN group of companies:
Your local, regional and global communications, IT or HR department. In addition, personnel in other departments may have access due to the global nature of HEINEKEN’s operations, such as local or global legal departments. Completion data will be shared with your line manager. The People Function will receive completion date, scores, survey data and statistics on the time spent on training.
Law enforcement or other regulatory or similar bodies:
Any law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
Your personal data are transferred outside of your country, subject to appropriate safeguards.
360Learning is a platform that is provided to HEINEKEN by 360Learning UK Limited. The data is primarily hosted with Microsoft Azure in the France Central Region, which consists of several physical locations and can be accessed by 360Learning to manage the platform and provide its services. Generally, data will mainly be processed within the European Economic Area and in the country where an OpCo is located. EC Standard Contractual Clauses, HNK Binding Corporate Rules (upon approval) or o...
We may transfer your personal data to affiliates or third parties that are based outside of the European Economic Area (“EEA") that may not be subject to the same level of data protection as exist within the EEA. When affiliates or third parties outside the EEA are given access to your personal data, we use Standard Contractual Clauses approved by the European Commission to ensure an adequate level of protection or Binding Corporate Rules (upon approval).
HEINEKEN is committed to safeguarding your personal data.
HEINEKEN has implemented various technical, physical and organisational measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. We use, for example, encryption for some of our services, we apply authentication and verification processes for access to HEINEKEN services and we regularly test, assess and evaluate the effectiveness of our security measures.
We have entered into a data processing agreement with 360Learning UK Limited.
How long is your data retained?
In general, we will retain personal data only for as long as needed to provide access to 360Learning and to demonstrate that employees have completed courses. AI prompts are deleted after 30 days. Personal details, account management details, training and usage data, and your content will be kept as long as 360Learning is in use within HEINEKEN or until the employment with HEINEKEN ends (whichever is earlier). In some cases, retaining training records is required by local law.
You have several rights in relation to your personal data. You can request us:
You also have the right, on the basis of grounds related to your particular situation, to object to processing your personal data. This does not apply where we have prevailing legitimate interests for the processing, in which case we will continue processing your personal data.
Please refer to the Contact section if you wish to exercise any of your rights or for questions or complaints you may have regarding your personal data.
We will keep this Privacy Notice under review and amend it from time to time. You are advised to regularly review this Privacy Notice for possible updates. This Privacy Notice was last updated in March 2025.
If you have any other question or a complaint about the processing of your personal data, please contact us via this webform with your data privacy request.
The contact details of HEINEKEN International B.V. are:
HEINEKEN International B.V.
Tweede Weteringplantsoen 21
1017 ZD Amsterdam The Netherlands.