Privacy Statement

The purpose of this privacy policy (“Policy“) is to set out how Solera Beverages BeLux treats the personal data (“data“; “personal data“; “information“) of users, prospects, suppliers, job applicants, and partners (“data subjects“, “you“, “your”) that we collect or that you provide to us.

We invite you to read it carefully so that you understand our practices regarding your personal data and how we use them.

In this Policy, you will find information about :

  1. Who are we (the identity of the data controller)?
  2. What is our commitment to protecting personal data?
  3. How do we collect your personal data (sources)?
  4. What categories of personal data do we collect and for what purposes?
  5. On what (legitimate) grounds do we process your personal data?
  6. Cookies
  7. Who has access to your personal data?.
  8. Where do we process your personal data?
  9. Subcontracting
  10. What are your rights with regard to personal data?
  11. What retention periods apply?
  12. What level of security do we guarantee?
  13. Policy update
  14. How can you contact us?

1.     Who are we (the identity of the data controller )?

The party responsible for processing your data is: Solera Beverages BeLux, whose registered office is at Da Vincilaan 9, 1930 Zaventem, Belgium, under number 1010.120.881 (“Solera Beverages“, “we“, “us“, “our“). By visiting our website, you are accepting the practices described in this Policy.

We will be happy to answer any questions or queries you may have about this Policy and how we handle your information more generally. You can contact us by email at: GDPR@Royalunibrew.com.

2.     What is our commitment to protecting personal data?

Solera Beverages is committed to using its best efforts to make its Data processing activities compliant with applicable data protection legislation, including Regulation (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR“) and any corresponding or equivalent national laws or regulations in (collectively “Applicable Data Protection Legislation“).

3.     How do we collect your personal data (sources)?

Depending on the nature of your relationship with Solera Beverages, we may collect your data, directly or indirectly, in a number of ways:

  • As part of and in the course of contractual and pre-contractual relations with data subjects and the provision of our services;
  • When personal data is provided directly by you or collected with your permission (e.g. via the contact form);
  • When you take part in promotional campaigns, competitions or prize draws;
  • When you interact with us on social networks (e.g. Facebook, Instagram), follow our content, or connect to our social networks via our website;
  • When you contact us directly by e-mail, telephone, post, message, online forms, or in any other way; or
  • When you visit our website ;

We may also collect information on third party sites (e.g. LinkedIn, etc.) when, for example, you apply for a job with us. Finally, we also collect information that we receive from other sources. We work with third parties who may share information with us.

4.     What categories of personal data do we collect and for what purposes?

We process personal data as part of our relationship with the individuals concerned.

4.1. Uses (purposes)

Generally for:

  • Providing you with our services;
  • Manage your customer or prospect file;
  • Manage marketing communications (including on social networks) and respond to your requests, send you information about our products, promotions and events;
  • Securing, maintaining and supporting our networks, systems and applications;
  • Provide you with information about other services we offer that are similar to those you have already used or enquired about;
  • To fulfil our obligations under any contract entered into between you and us and to provide you with the information and services you request from us;
  • To administer our terms and conditions with you (including, without limitation, the billing of our services) and to resolve any disputes relating to our terms and conditions;
  • Answering general questions about our services or terms and conditions;
  • Handling your enquiries;
  • To comply with applicable laws, if any ;
  • If it is reasonably necessary in the context of a dispute in which we are or may be involved, either directly with you or with a third party;

For direct marketing

  • If you have consented to receive marketing communications from us by email, you may change your mind and withdraw that consent. You can withdraw your consent by clicking on the unsubscribe link at the bottom of the email you have received: You can also send an e-mail to the following address: GDPR@Royalunibrew.com

To protect Solera Beverages

  • We may process certain personal data where processing is necessary for the establishment, exercise or defence of Solera Beverages’ legal claims (including determining our liability);
  • To manage disputes with the parties concerned, such as our suppliers;
  • To enforce our terms and conditions, and to keep records of this enforcement, including using your data to analyse whether you have breached our terms and conditions (for example by acting fraudulently).

We may also process your personal data

  • To carry out corporate restructuring operations;
  • To fulfil our contractual and/or legal obligations;
  • For internal and external audits;

If, from time to time, we need to process your personal data for a purpose other than those mentioned above, we will inform you of this new purpose, within the limits authorised by law, insofar as this is legally necessary.

4.2. Categories of personal data

The personal data we process includes:

  • Personal identification data (e.g. surname, first name, e-mail address) to provide you with services defined in the context of a contract concluded with you (general terms and conditions of sale), to manage your customer file or prospect file and to process your requests for information;
  • Technical/electronic data (including the IP address used to connect your computer to the Internet, browser type and version, time zone, browser plug-in type and version, operating system and platform, device identifier) during your visit to our website for the purposes of providing IT support, detecting and preventing fraud and computer security breaches;
  • Data relating to your use of our website (pages viewed, links clicked, time spent on a page, etc.), processed in aggregate form and solely for the purpose of improving the user experience on our website and ensuring that content is presented in the most effective manner for you and your computer/device;
  • Data of a professional nature (e.g. job responsibilities, name, place of work) for the purpose of examining and evaluating your application when you apply via our website or a third-party site (e.g. LinkedIn);
  • Social network data (e.g. interactions with our social network accounts, tracking and sharing of our content) to manage marketing communications (including on social networks);
  • General information about you when you contact us by e-mail, post, telephone or any other communication channel, for example in order to respond to any questions or requests you may have;
  • Data we receive about you from other sources, which must be processed in accordance with the purposes described above.

We do not collect data relating to payment orders (e.g. data identifying the persons concerned; the amount and currency of the payment transaction; the international bank account number (“IBAN”) where the bank account is identified using an IBAN code, or the corresponding bank account code, as the case may be). This personal data is only collected by our service provider.

We do not collect “sensitive” data (within the meaning of the RGPD).

5.     On what (legitimate) grounds do we process your personal data?

Your personal data is collected and processed on the following legal grounds:

  • The performance of a contract (general terms and conditions) to which you are a party or the performance of pre-contractual measures taken at your request (art. 6(1), b) of the RGPD). For example: to answer general questions about our services or our general terms and conditions;
  • Safeguarding our legitimate interests by considering that these interests do not override your fundamental rights and freedoms (art. 6(1), f) of the GDPR). For example, we use your personal data to find out your preferences so that we can better personalise our services;
  • The fulfilment of a legal obligation or regulatory requirement to which we are subject (art. 6(1), c) of the GDPR) insofar as in force and applicable, including any amendments, modifications or replacements made from time to time (e.g. in relation to invoicing or taxation; for the management of disputes with customers and other data subjects);
  • Your consent (art. 6(1), a) of the GDPR). For example, if you have given your prior formal consent to processing, we may use your email address to send you marketing communications. In this case, you may revoke the consent you have given us at any time. Please note, however, that data processing remains authorised as long as no objection has been made.

We do not subject data subjects to decisions based exclusively on automated processing that produces legal effects concerning them or affects them in a similarly significant way.

The possible consequences of not providing your data could include our inability to fulfil our obligations under a contract or a breach by us of one or more obligations under applicable legislation (e.g. accounting or tax legislation).

6.     Cookies

Our website uses cookies and/or other similar technologies. These cookies help us to provide you with a pleasant browsing experience on our website and also enable us to improve it. For detailed information on the cookies we use and the purposes for which we use them, please refer to our Cookie Policy.

7.     Who has access to your personal data ?

You authorise us to share or transfer some of your data with our recipients insofar as this is necessary and authorised in accordance with the legislation in force and for the purposes described above, including :

  • Our internal departments if and insofar as this is necessary to fulfil certain legal obligations or to safeguard our legitimate interests. This may be the case, for example, for internal administrative purposes;
  • Our (commercial) partners, including our suppliers and stakeholders;
  • Public authorities (including judicial authorities and regulators) where applicable ;
  • Our professional advisers (e.g. lawyers, consultants) if applicable ;
  • Recruitment service providers ;
  • Suppliers of analysis and search engines who help us to improve and optimise our website;
  • The courts and tribunals of the judicial system in the event of a dispute involving you;
  • Government bodies legally entitled to access and/or obtain your data;

Finally, we will also disclose your personal data to third parties:

  • In the event of the sale or purchase of a business or assets, in which case we may disclose your data to the prospective seller or buyer of that business or assets;
  • If we are required to disclose or share your data in order to comply with any legal obligation or to protect the rights, property or safety of Solera Beverages or third parties. This may include exchanging data with public authorities (including judicial authorities, police and regulators) in the event of, for example, a cyber incident;
  • If this disclosure is necessary to achieve one of the purposes set out in this Policy.

8.     Where do we process your personal data?

We take care to host the personal data of participating data subjects exclusively on servers located within the European Economic Area (“EEA”). Solera Beverages will therefore not transfer your data outside the EEA. Should this be the case, however, we will ensure that such personal data is protected by adequate safeguards, including (but not limited to) the laws of the country of destination of the personal data which guarantee an adequate level of data protection, data protection clauses approved by the European Commission, or binding corporate rules.

If you would like to receive further information about transfers of your personal data and/or the protection measures implemented, you can contact us by e-mail at: GDPR@Royalunibrew.com

9.     Subcontracting

We take appropriate measures to ensure that our sub-contractors process your data in accordance with data protection laws.

For example, we ensure that our subcontractors undertake, among other things, to process your data only on our instructions, not to engage another subcontractor without our consent, to take appropriate technical and organisational measures to guarantee the security of your data, to ensure that persons authorised to access your data are subject to confidentiality obligations, and to provide us with assistance in following up your requests to exercise your rights in relation to your data.

10.  What are your rights with regard to personal data?

Subject to the limitations contained in Applicable Data Protection Legislation, you have certain rights in relation to the data we hold about you. These rights may be exercised by contacting us.

  • The right to be informed. You have the right to be informed in a clear, transparent and easily understandable way about how we use your data and about your rights. This is why we provide you with all this information in this Policy;
  • The right of access. You have the right to access the data we hold about you. This is because we want you to be aware of the information we hold about you and we want to give you the opportunity to check that we are processing your data in accordance with Applicable Data Protection Legislation;
  • The right to restrict processing. You have the right, in certain circumstances, to “block” or interrupt the future use of your data. When processing is restricted, we are still entitled to keep your data, but we can no longer use it;
  • The right to rectification. If your personal data is incorrect or incomplete, you have the right to request that it be rectified;
  • The right to erasure. You have the right to have your data erased. However, the right to erasure (or the “right to be forgotten”) is not absolute and is subject to specific conditions. We may retain your data to the extent permitted by applicable law, in particular where processing remains necessary for compliance with a legal obligation to which Solera Beverages is subject or for the establishment, exercise or defence of legal claims;
  • The right to lodge a complaint. You have the right to lodge a complaint about the way in which we handle or process your data with the competent national authority. In Belgium this is : The Data Protection Authority, Rue de la Presse 35, 1000 Brussels, +32 (0)2 274 48 00, contact(at)apd-gba.be, https://www.autoriteprotectiondonnees.be/ ;
  • The right to withdraw your consent. If our processing of your data is based specifically on your consent, you have the right to withdraw your consent at any time;
  • The right to portability of your data. You have the right to receive from us, in certain circumstances, your data in a structured, commonly used and machine-readable format so that you can re-use it for your own purposes in the context of separate services;
  • The right to object to processing. You have the right to object to your data being used for a specific purpose on “grounds relating to your particular situation”;
  • The right not to be subject to an automated individual decision. You have the right to object to a fully automated decision, i.e. a decision where there is no human intervention that (effectively) contributes to the decision and therefore cannot modify the decision. We do not make any fully automated decisions about data subjects;

Please note, however, that we may retain certain information, for example for legal or administrative purposes.

To exercise the above requests, please send us an e-mail to GDPR@Royalunibrew.com with “data protection request” in the subject line and attach a copy (front) of your identity card or other document proving identity (e.g. your driving licence) to help us prevent unauthorised persons from accessing, modifying or deleting your personal data. We will respond to your request as quickly as possible. If it takes longer than one month (from receipt of your request) to respond to your request, we will contact you to let you know.

11.  What retention periods apply?

We ensure that your data is kept for no longer than is necessary for the purposes for which it is processed.

In determining the relevant retention periods and unless otherwise stated below, we will take into account factors such as:

  • Our contractual rights and obligations in relation to the data concerned ;
  • Legal obligations, under applicable law, to retain data for a certain period ;
  • Limitation periods under applicable law ;
  • Our legitimate interests in processing where we have carried out balancing tests;
  • Guidelines issued by the competent data protection authorities ;
  • Security reasons (for example, the security of our information systems);

Unless:

  • The processing of your personal data is necessary in the event of actual or potential litigation (e.g. to establish or defend legal claims), in which case we will retain your personal data until the outcome of that litigation; and/or
  • Retention is necessary to fulfil a legal or regulatory obligation (e.g. for tax purposes), in which case we will retain your personal data for as long as required by that obligation.

12.  What level of security do we guarantee?

We take appropriate technical and organisational measures to ensure a level of security appropriate to the risks associated with processing your data. For example, we have taken reasonable technical and organisational precautions to protect data against unauthorised or unlawful access. We follow industry best practice to ensure that data is not accidentally or unlawfully destroyed, lost, altered, disclosed in an unauthorised manner or accessed in an unauthorised manner.

13.  Policy update

We reserve the right to update this Policy from time to time. Any changes we make will be posted on this page and, where appropriate, notified to you by email. Please check this page frequently for updates or changes. Your continued use of this website following the posting of changes to this Policy constitutes your acceptance of those changes.

In the event of any conflict or inconsistency between any provision of this Policy and any provision of any other Solera Beverages policy or document relating to data processing, the provision of this Policy shall prevail.

This Policy was last updated on February 2025.

14.  How can you contact us?

If you have any questions or comments about this Policy, you may send them in writing to the following address: For the attention of Solera Beverages Legal Department, Da Vincilaan 9, 1930 Zaventem, Belgium, or by email to GDPR@Royalunibrew.com.