The “Probably Better Now” movement is an initiative promoted by the Carlsberg brand, which is marketed in Portugal by SUPER BOCK BEBIDAS S.A. (hereinafter “SUPER BOCK”).
At SUPER BOCK we recognize the importance of processing the personal data entrusted to us, which is why we are committed to processing your personal data in a transparent, secure, complete and confidential manner, taking only clear and precise purposes into account.
Therefore, we invite you to take a few minutes of your time to read this policy, in which you can find the terms and conditions for the processing of your personal data when using the website probablybetternow.com (hereinafter “website” or “platform”). Among other information, you will find out who processes your data, for what purposes the data are processed, how they are processed, with whom they are shared, for how long they are retained, as well as ways to contact us and to exercise your rights.
The data collected through the website will be processed by SUPER BOCK BEBIDAS, S.A., a company headquartered at Via Norte, 4465-764, Leça do Balio – Matosinhos – Portugal, hereinafter “SUPER BOCK” or “we”/“us”. This is the entity responsible for the processing of your personal data (“controller”), as it defines the data to be collected, the purposes of collection and the means of processing.
Personal data is considered to be any and all information relating to a natural person, identified or likely to be identified.
A data subject is anyone to whom the personal data relate. Thus, in the present context, all website users, who may be qualified as participants or potential participants in the initiatives that are disclosed and/or made available on the platform, as well as the representatives and/or contact persons of the partner entities, are considered personal data holders.
SUPER BOCK collects and processes your personal data, as a website user, for the following purposes:
Purpose | Processing Activities |
Website Management | Account creation, authentication and access management. |
Analysis and processing of web browsing data. | |
Management of Initiatives | Ensure registration in initiatives that may be promoted and/or disclosed on the website. |
Relationship Management with Partners | Ensure the registration of partners, in order to ensure that they can disclose the initiatives they intend to promote on the platform. |
Collection of suggestions and contributions | Register the suggestions and contributions that users intend to make and/or disclose on the website. |
Marketing Activities | Send information about initiatives and events that may be promoted within the scope of the “Probably better now” movement. |
Send direct commercial information (email, sms, mms, etc.) about services and products marketed by SUPER BOCK (for example, via newsletter). | |
Manage your participation in contests, events and other marketing initiatives promoted and disclosed through the website. |
In order to guarantee the achievement of the purposes identified in point 3, SUPER BOCK needs to collect the following categories of personal data:
The legal basis that allows us to process your personal data varies depending on the specific processing activity for which such data is collected and processed, as explained in the table below:
Processing Activities | Legal Basis |
Account creation, authentication and access management. | Execution of the contract, the terms of which are governed by the Terms and Conditions of Use of the Website (“Contract”). |
Analysis and processing of web browsing data. | |
Ensure registration in initiatives that may be promoted and/or disclosed on the website. | The processing of data is justified in our legitimate interest and in the need to proceed with the pre-contractual measures requested by you. Without personal data, it will not be possible to respond to the action requested by you, that is, it will not be possible to ensure your registration in the initiative. |
Ensure the registration of partners, in order to ensure that they can disclose the initiatives they intend to promote on the platform. | The processing of the data of the representatives and contact persons of the partner entities is justified in our legitimate interest and in the need to proceed with the requested pre-contractual measures. Without personal data it will not be possible to ensure the registration of partner entities and, without registration, partner entities will not be able to disclose their initiatives. |
Register the suggestions and contributions that users intend to make and/or disclose on the website. | The legal basis for registering suggestions and contributions is based on our legitimate interest in improving and increasing the number of initiatives that allow us to energize and expand the “probably better now” movement. |
Send direct commercial information (email, sms, mms, etc.) about services and products marketed by SUPER BOCK (for example, via newsletter). | The processing of your data for this activity will only be carried out with your consent. |
Send information about initiatives and events that may be promoted within the scope of the “Probably better now” movement. | The use of personal data for the purpose of sending information and disclosing initiatives within the scope of the “Probably Better Now” movement will only be carried out based on your consent. |
Manage your participation in contests, events and other marketing initiatives promoted and disclosed through the website. | The use of the personal data you provide us with to manage your participation in contests and other marketing initiatives is based on our legitimate interest in promoting initiatives that improve communication and the relationship with our consumers or in the execution of a contract, which it is entered into when the user accepts the terms and conditions of participation provided for in the regulations published at each moment. |
Whenever the legal basis for the processing of your personal data is consent or legitimate interest, you have the right to withdraw consent or oppose the processing, respectively, and may do so at any time, although this right does not compromise the legality of the processing in the meantime carried out based on the legitimate interest or consent previously given, nor the subsequent processing of the same data based on any other legal basis, such as in the case of compliance with the contract or a legal obligation to which SUPER BOCK is subject.
If you would like to know more about your rights and how you can exercise them, please refer to points 9 and 10 of this policy below.
SUPER BOCK retains your personal data only for the period strictly necessary to pursue the purpose they were collected for.
In this sense, personal data collected and processed within the scope and for the purpose of the processing activities identified in point 3 will be retained for the following periods:
Processing Activities | Retention Period |
Account creation, authentication and access management. | For the duration of registration on the Website. |
Ensure registration in initiatives that may be promoted and/or disclosed on the website. | For a period of 2 years. |
Ensure the registration of partners, in order to ensure that they can disclose the initiatives they intend to promote on the platform. | For a period of 2 years. |
Register the suggestions and contributions that users intend to make and/or disclose on the website. | For a period of 2 years. |
Send direct commercial information (email, sms, mms, etc.) about services and products marketed by SUPER BOCK (for example, via newsletter). | When consent is the legal basis, the data will be retained for a period of 5 years from the date of collection of your consent or the last contact made (whichever occurs last) as long as you have not withdrawn your consent within this period. |
Send information about initiatives and events that may be promoted within the scope of the “Probably better now” movement. | When consent is the legal basis, the data will be retained for a period of 5 years from the date of collection of your consent or the last contact made (whichever occurs last) as long as you have not withdrawn your consent within this period. |
Manage your participation in contests, events and other marketing initiatives promoted and disclosed through the website. | For the duration of the contest, event or initiative. |
Once the maximum period of retention indicated in the table has been reached, SUPER BOCK will proceed with the deletion or anonymization of your personal data, unless retention is necessary for the purposes of declaration, exercise or defence of a right in legal proceedings by SUPER BOCK, in which case the data can be retained for a longer period.
The anonymization of your personal data means that it is no longer possible to make your identification, which means it is impossible to relate identification data, contact data, transactional data and data constructed with the respective data subject.
SUPER BOCK transmits your personal data only when necessary to carry out the purposes described in this policy.
Thus, SUPER BOCK may disclose and share your personal data with other SUPER BOCK GROUP companies, exclusively for administrative and internal purposes.
SUPER BOCK may also disclose and share your personal data with third party suppliers and/or service providers, such as technological service providers, logistics, transport and delivery service providers and collaborators, service providers related to customer support, partners and service providers related to marketing, advertising and promotion of events, and only the data necessary for the development of the activity pursued by these entities within the scope of the purposes identified in this privacy policy will be transmitted.
Thus, the personal data made available for the purpose of registration on this website, as well as the data provided for the purpose of registering in the initiatives disclosed on the “Probably Better Now” platform, will be processed by the company CREAKT, LDA, hereinafter “CREAKT”, and by the company SA365, Agência de Comunicação, Lda., hereinafter “SA365”, who act in the name and on behalf of SUPER BOCK in the development, implementation and management of the “Probably Better Now” movement, processing, in this context, the personal data essential to the fulfillment of the processing purposes described in this document. CREAKT and SA365 guarantee compliance with the obligations set forth in these Terms and Conditions and the adoption of the technical and organizational measures necessary to comply with the principles and rules contained in the GDPR, which are specifically enshrined in the personal data processing agreement entered into with SUPER BOCK, in full compliance with current legislation on data protection.
In addition to CREAKT and SA365, there are other third parties, suppliers/partners of SUPER BOCK (data controller) and of CREAKT and SA365 (subcontractors), who may have access to the personal data provided. These third parties access the data for the purpose of providing the services and/or complying with the obligations arising from the legal relationships they established with SUPER BOCK or CREAKT or SA365, in the context of the development, implementation and management of the “Probably Better Now” movement.
The personal data made available within the scope and for the purpose of registering the initiatives disclosed on the website will also be transmitted to the partner entities promoting the different initiatives on the “Probably Better Now” platform, who shall act as Data Controllers as soon as the data are made available to them by SUPER BOCK.
It should be noted that the inclusion of links to other websites does not automatically determine the transmission or disclosure of personal data to the managing entities of those destination domains. However, by clicking on the link, we no longer have any influence on the collection, storage or processing of any personal data transmitted (such as the IP address or URL of the page containing the link), as the behaviour of third parties, that is, of the managing entities of those domains, is, by nature, beyond our control. Therefore, SUPER BOCK shall not be responsible for the processing of personal data from the moment you click on the links, so we advise you to read carefully the privacy and processing of personal data policies on the target Websites.
SUPER BOCK makes use of physical, technological, organizational and security measures appropriate to the protection of your personal data in order to protect the personal data made available from disclosure, loss, misuse, alteration, processing or unauthorized access.
SUPER BOCK guarantees the applicability and compliance with all the rights of the holder of personal data provided for in the General Data Protection Regulation and national legislation in force.
Rights | What do they consist of? |
Right to provide information | The Data Subject has the right to obtain clear, transparent and easily understandable information about how SUPER BOCK uses their personal data and what their rights are. It is for this reason that SUPER BOCK provides all this information in this Privacy Policy. |
Right of access | The Data Subject has the right to obtain information about the personal data concerning them that are being processed by SUPER BOCK (if any) and information (similar to that provided in this Privacy Policy) about how this data are processed. SUPER BOCK may refuse to provide the requested information whenever, in order to do so, it has to reveal another person's personal data or the information negatively impacts another person's rights. |
Right of rectification | If the Data Subject's personal data are incorrect or incomplete (for example, if their name or address is wrong), they may ask SUPER BOCK to take reasonable steps to correct them. |
Right to Delete Personal Data | This right is also known as the "right to be forgotten" and, simply, allows the Data Subject to request the deletion or elimination of their data, provided that there are no valid grounds for SUPER BOCK to continue to use them. This is not a generic right to deletion, as exceptions are allowed (for example, whenever these data are necessary for the defence of a right in legal proceedings). |
Right to restriction of processing | The Data Subject has the right to “block” or prevent the future use of their Data while SUPER BOCK evaluates a request for rectification or as an alternative to deletion. Whenever the Processing is restricted, SUPER BOCK continues to be able to store your data, but will not be able to use them later. |
Right to the portability of Personal Data | The Data Subject has the right to obtain and reuse certain personal data for their own purposes in various organizations. This right only applies to your own data provided to SUPER BOCK and which are processed based on your consent or a contract and by automated means. |
Right to Opposition | The Data Subject has the right to oppose to certain types of processing, for reasons related to their particular situation, when such processing is based on the legitimate interest of SUPER BOCK or third parties. SUPER BOCK may continue to process such Data if it proves "overriding legitimate reasons for the processing that prevail" over the interests, rights and freedoms of the Data Subject or if such data are necessary for the establishment, exercise or defence of a right in a court case. |
Right to file a complaint | The Data Subject has the right to file a complaint with the competent supervisory authority, the National Data Protection Commission – CNPD, if they consider that the Processing carried out on Personal Data violates their rights and/or Data Protection Legislation. |
You can exercise your rights by sending your request directly to the email address privacy@superbockgroup.com. We will answer within a maximum period of 30 days, unless the assessment of the request is particularly complex.
The process will be handled free of charge, unless a manifestly unfounded or excessive request is at stake, in which case the Data Controller may demand payment of a fee, taking into account any costs incurred in answering the request.
Please be advised that you may need to provide proof of your identity to ensure that the rights are being exercised by the relevant holder.
Please note that SUPER BOCK has a Data Protection Officer (DPO), who can be contacted through the email address privacy@superbockgroup.com and provide you with any clarification or receive any complaint related to the processing of your personal data.
Even so, and if you are not satisfied with our response after exercising any of these rights, you have the right to file a complaint with the competent Supervisory Authority:
SUPER BOCK reserves the right to update this Privacy Policy at any time.
Therefore, it is recommended that you periodically consult this policy on the website probablybetternow.com in order to stay informed about the terms and conditions for the processing of your personal data.
This Privacy Policy was last updated in August 2021.