Privacy Notice applicable to

Personal Data processed in the context of www.cocacola.co.uk

 

 

LAST REVISED: [May 22, 2016]

 

1. General Privacy Statement

2. What Personal Data do we collect about you?

3. How do we collect your Personal Data?

4. How do we use your Personal Data?

5. What profiling do we perform?

6. To whom is your Personal Data disclosed?

7. Third party sites / third party service providers

8. Third party advertising related vendors

9. What are your rights with regards to the processing of your Personal Data, how can you exercise them and how can you contact us?

10. How long do we keep your Personal Data?

11. Use of Sites by minors and warning for the parents

12. What transfers of Personal Data outside the European Economic Area do we carry out?

13. Applicable law

14. Updates to this Privacy Notice 

 

 

1. General Privacy Statement

 

a. The following privacy notice (the "Privacy Notice") sets out our policy for processing your personal data that we collect through

- our website at www.cocacola.co.uk (the "Website"), 

- the affiliate app (the "App"); and through 

- the affiliate social media page (the "Social Media") (collectively, the "Sites"). 

Personal data is information directly or indirectly relating to you as an individual ("Personal Data"). 

b. NV Coca-Cola Services SA, which has its registered office at Chaussée de Mons 1424, 1070 Brussels ("CCS"), is the data controller (within the meaning of EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC, hereinafter referred to as the "General Data Protection Regulation"), responsible for processing your Personal Data in connection with the Sites (hereinafter referred to as "we", "us" and "our").

c. You have the opportunity to review this Privacy Notice by clicking on a link entitled "Privacy Notice" located at the bottom of each of the Website's page, on the Social Media and on the page where you can download our App. We request that you read this Privacy Notice carefully. 

d. You can browse our Sites, learn about exciting things while on them and share content with others. You can also create an account to access all Sites linked to the Coca-Cola central Consumer Interaction Database (the "Account") and participate to promotions. To learn how we use your Personal Data when you register for an account, please refer to this privacy notice. The present Privacy Notice is applicable to all users of our Sites, whether they are registered or not. 

 

 

2. What Personal Data do we collect about you? 

 

a. The Personal Data we collect and process about you

We collect and process the following information about you:

· Surname

· First name

· Gender

· Date of birth

· User name

· Postal address

· Telephone number (including home and mobile phone numbers)

· Email address

· Social Media public profile: name, handles, photos, "likes", location, other public profile information

· User created content on the Social Media: photos, texts, videos, symbols, hashtags, recordings that you share on the Social Media

· Location information

· Hobbies and interests

· Consumption habits

· Browser and device information: IP address, MAC address, Google Ad ID, Identity For Advertisers (device ID)

· Server log file information

· App usage data

· Activity / Engagement Personal Data (e.g. data and time of activity on relevant Sites, number of times a Site is visited, which items are clicked).

 

b. We ask you not to send us or disclose any Sensitive Information on or through the Sites or otherwise to us.

“Sensitive Information” is Personal Data related to sensitive aspects such as:

· racial or ethnic origin

· political opinions

· religion or other beliefs

· health or medical condition

· criminal background

· trade union membership

· sexual orientation.

 

 

3. How do we collect your Personal Data? 

 

We collect your Personal Data as follows:  

· Through the Sites:  We collect Personal Data through the Sites.

· Offline:  We collect Personal Data from you offline, such as when you contact customer service;

· When you download the App:  when you download and use the App, we track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number;

 

· Physical Location: we collect the physical location of your device by, for example, using satellite, cell phone tower or Wi-Fi signals;

 

· Using cookies: we collect your Personal Data when you browse the Sites, by using cookies. Our collection and processing of your Personal Data via cookies are governed by the Cookie Policy, that you should read carefully. You can accept or reject cookies (except Strictly Necessary Cookies defined in the Cookie Policy), by setting or de-setting the relevant tick-boxes in the Preference Center available here;

The Personal Data you provide through the Sites is combined with Personal Data and other Information that you provide to us (via online or offline means), or that we otherwise obtain online or offline.

 

 

4. How do we use your Personal Data? 

 

We use your Personal Data for the following purposes:  

a. Respond to your requests / Administrative interactions

· To respond to your inquiries, questions and comments and fulfil your requests.

Legal basis for processing: our legitimate interests to answer your queries.

· To send administrative information to you, such as for example information regarding the Sites, changes to our terms and conditions, and changes to this Privacy Notice.  

Legal basis for processing: our legitimate interests to inform you about the evolution of our Sites, the changes to our terms and conditions, and the changes to this Privacy Notice, in a timely manner.  

b. Data analytics using your Social Media public profile and shared contents

· We collect your Personal Data to measure your engagement with our Social Media and analyze your interests. Concretely, we collect the contents that you share on the Social Media and your Social Media public profile, to analyze this information and derive consumption trends and patterns. This helps us to know our Social Media users better, what they like, how they react to our products, services and contents. By better knowing our Social Media' users, we can adapt our Sites to the identified preferences of users, but also more generally improve Coca-Cola products and services.

Legal basis for processing: your consent

You have the opportunity to accept or refuse this collection and use of your Personal Data for abovementioned purpose, by setting your privacy preferences on the privacy dashboard accessible on the Sites. You just have to click on the relevant tick-box if you want to have your Personal Data processed for the purpose of allowing us to perform data analytics using your Social Media public profile and shared contents to derive trends and improve our Sites and more generally Coca-Cola products and services, and "de-click" the tick-box if not. The tick-box is unticked by default.

You can withdraw your consent to the collection and use of your Personal Data for the abovementioned purpose by acceding to the privacy dashboard accessible on the Sites and "de-clicking" the relevant tick-box. You can also let us know that you wish to withdraw your consent by email, by calling us or writing to us using the contact information listed in section 9 of this Privacy Notice. Once you withdraw your consent, we will stop the processing for the concerned purpose.

c. Data analytics pertaining to your activity on the Sites

·  We collect your Personal Data, including location data, to measure your engagement with the Sites (e.g. to know how you use our Sites, when do you use them, how often, using what device, how long you stay on them, on what items you click), and derive consumption trends and patterns from this analysis. This helps us to know the Sites' users better, and adapt our Sites to the identified preferences of the users, but also more generally improve Coca-Cola products and services.

Legal basis for processing: your consent

You have the opportunity to accept or refuse this collection and use of your Personal Data pertaining to your activity on the Sites for the purpose of performing data analytics to derive trends and improve our Sites and more generally Coca-Cola products and services, by setting your privacy preferences on the privacy dashboard accessible on the Sites. You just have to click on the relevant tick-box if you want to have your Personal Data processed for the purpose of allowing us to perform data analytics to derive trends and improve our Sites and more generally Coca-Cola products and services, and "de-click" the tick-box if not. The tick-box is unticked by default.

You can withdraw your consent to this collection and use of your Personal Data for the abovementioned purpose by acceding to the privacy dashboard accessible on the Sites and "de-clicking" the relevant tick-box. You can also let us know that you wish to withdraw your consent by email, by calling us or writing to us using the contact information listed in section 9 of this Privacy Notice. Once you withdraw your consent, we will stop the processing for the concerned purpose.

d. Storing and sharing of the contents that you publish on the Social Media

· You can share content on our Social Media, such as pictures of yourself, texts, hashtags, videos and recordings. When you communicate such content on our Social Media, we can decide to share some of this content (and your Social Media public profile) on our Sites, in the context of marketing campaigns, and more generally to present and highlight our Sites, Coca-Cola products and Coca-Cola services. When we do so, we store your Personal Data in the Coca-Cola central Consumer Interaction Database

Legal basis for processing: your consent

You have the opportunity to accept or refuse this collection and use of your Personal Data for the abovementioned purpose by setting your privacy preferences on the privacy dashboard accessible on the Sites. You just have to click on the relevant tick-box if you want to have your Personal Data processed for the purpose of allowing us to store and share on our Sites the contents that you publish on the Social Media, and "de-click" the tick-box if not. The tick-box is unticked by default..

You can withdraw your consent to the collection and use of your Personal Data for the abovementioned purpose by acceding to the privacy dashboard accessible on the Sites and "de-clicking" the relevant tick-box. You can also let us know that you wish to withdraw your consent by email, by calling us or writing to us using the contact information listed in section 9 of this Privacy Notice. Once you withdraw your consent, we will stop the processing for the concerned purpose.

e. IT administration

· We use your Personal Data to diagnose server problems, administer the Sites and check that they function properly.

Legal basis for processing: our legitimate interests to administer our IT systems and networks, to ensure the proper functioning of the Sites.

f. Transactions

In the event that you conduct a transaction via the Sites, such as purchasing Coca-Cola and affiliated brands merchandise, we record the payment details you provide for such transaction, along with any other Personal Data, such as the address to which the products you purchase are to be sent. We use your Personal Data to complete the transaction and your purchase.

Legal basis for processing: the processing of your Personal Data to complete transactions is based on the performance of your purchase contract.

g. Compliance with our legal obligations

· To comply with our legal obligations, legal proceedings or government authorities' orders which can include orders from government authorities outside your country of residence, when we reasonably believe that we are legally required to do so and when disclosing your Personal Data is strictly necessary to comply with the said legal obligations, proceedings or government orders.

Legal basis for processing: compliance with our legal obligations.

g. Lawful protection of our interests

· To lawfully enforce our terms and conditions, protect our operations or those of any of our affiliates, protect our rights, privacy, safety or property, and/or that of our affiliates, and allow us to pursue available legal remedies or limit the damages that we may sustain.

Legal basis for processing: our legitimate interests to lawfully protect our organization.

 h. Corporate / M&A operations

· To perform any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Legal basis for processing: our legitimate interests to conduct our corporate strategy.

 

 

5. What profiling do we perform?

 

a.  We use your Personal Data to perform scoring and profiling in an automated way, with the help of Google UID. This scoring and profiling is carried out to attain the following purposes described in section 4 of the Privacy Notice: (i) Data analytics pertaining to your activity on the Sites and (ii) Data analytics using your Social Media public profile and shared contents.

b. This profiling does not have any legal consequences on you, nor does it have any effect on your experience of the Sites. It does not involve any monitoring or tracking of your individual behaviour, action or movement in any way. It is only used to help us know preferences and behaviours of Sites' users in general, and from this analysis, improve the Sites, Coca-Cola products and Coca-Cola services.

 

 

6. To whom is your Personal Data disclosed?

 

Your Personal Data is disclosed to the following recipients:

a. local entity

b. Adobe Managed Services, which hosts our IT systems and provides system support;   

c. APIGEE Edge Platform, which hosts our IT systems and provides system support;

d. Amazon Web Services (AWS) EC2, which hosts our IT systems and provides system support;

e. CI&T, which hosts our IT systems and provides system support (the agency which provides and maintains GO!Progressive);

f. DMeX, which hosts our IT systems and provides system support;

g. EPAM (responsible for CID programming, located in Hungary);

h. ExactTarget, which supports our IT system and performs data analytics for the purposes described in the Privacy Notice;

i. Gigigo (manages the Orchextra platform)

j. Gigya, which hosts our IT systems and provides system support;

k. Google, which supports our IT system and performs data analytics for the purposes described in the Privacy Notice;

l. ICP (provides content management services for DMeX);

m. Livefyre, which hosts our IT systems and provides system support;

n. Janrain, which hosts our IT systems and provides system support;

o. MicroStrategy, which hosts our IT systems and provides system support;

p. MRM-McCann, which hosts our IT systems and provides system support;

(manages the entire Journey platform) ;

q. Qualtrics, which hosts our IT systems and provides system support;

r. SalesForce, which hosts our IT systems and provides system support;

s.  SessionM, which hosts our IT systems and provides system support;

t.  Wayin DB ;

u. WordPress, which hosts our IT systems and provides system support;

v. Wunderman (campaign content management)

w. CIC contractor

x. As we believe to be necessary or appropriate, relevant authorities, affiliates and third parties: (a) to comply with our legal obligations; (b) to respond to requests from public and government authorities which can include public and government authorities outside your country of residence; (c) to enforce our terms and conditions; (d) to protect our operations or those of any of our affiliates; (e) to protect our rights, privacy, safety or property, and/or that of our affiliates; and (f) to allow us to pursue available remedies or limit the damages that we may sustain.

 

 

7. Third party sites / third party service providers  

 

This Privacy Notice does not address, and we are not responsible for, the processing and data protection practices of any third parties, including any third party operating any site to which these Sites contain a link. The inclusion of a link on the Sites does not imply endorsement of the linked site by us or by our affiliates.  

In particular, please note that the Sites can contain a link to e-commerce websites, including some e-commerce websites that are Coca-Cola branded.  This Privacy Notice does not govern any e-commerce websites to which the Sites can contain a link.  Any Personal Data that you provide through the e-commerce website will be subject to the privacy notice of the e-commerce site, and not this Privacy Notice.  We have no control over, and shall not be responsible for, the use of information collected through the e-commerce site.

In some cases, we may use a third party payment service  to process purchases and/or collect donations made through the Sites.  In these cases, your Personal Data may be collected by this third party and not by us, and will be subject to the third party’s privacy notice, rather than this Privacy Notice. We have no control over, and are not responsible for, this third party’s use or disclosure of your Personal Data and we do not endorse those third parties or their websites.  We do not make any representation as to the accuracy, completeness, timeliness or suitability of information in those third parties’ own privacy policies. It is your responsibility to read the privacy policies on third party websites carefully before you use them.  

 

 

8. Third party advertising related vendors

 

Please note that our online and email advertising-related vendors may use pixel tags, web beacons, clear GIFs or other similar technologies in connection with the Sites to help manage our online and email advertising campaigns and strengthen the effectiveness of such campaigns.  For example, if a vendor has placed a unique cookie on your computer, the vendor may use pixel tags, web beacons, clear GIFs or other similar technologies to recognize the cookie during your visit to the Sites and to learn which of our online advertisements may have brought you to our Sites, and the vendor may provide us with such other information for our use.  Please note we may link such other information provided to us by our vendors to Personal Data about you that we have previously collected.

We may use third-party advertising companies to serve advertisements on our Sites.  These companies may use information (not including your name, address, email address or telephone number) about your visits to the Sites in order to provide advertisements about goods and services of interest to you.  If you would like more information about this practice, please visit http://evidon.com, and to know your choices about not having this information collected or used by these companies, please visit http://www.evidon.com/consumers/profile_manager#tab3.

 

 

9. What are your rights with regards to the processing of your Personal Data, how can you exercise them and how can you contact us?

 

a. Your rights with regards to the processing of your Personal Data

You have the right:

· to be provided with a copy of any Personal Data that we hold about you;

· to request us to update or correct any inaccurate Personal Data, or complete any incomplete Personal Data;

· to request that we stop processing your Personal Data for direct marketing purposes.

You also have the right, in certain circumstances:

· to object to the processing of your Personal Data;

· to request us to delete your Personal Data;

· to restrict our processing of your Personal Data; and

· to request us to transmit certain of your Personal Data to you or to transfer or have them transferred to another data controller.

b. The exercise of your rights

If you wish to exercise any of your above rights, you can contact us using one of the options below.

 

· You can send us an email to the following address: [gbcic@coca-cola.com]

· You can call us on: 0800-227711

· You can write to the following postal address:

 

Consumer Interaction Center
PO Box 73229
LONDON
E14 1RP]

 

c. Right to lodge a complaint to the competent data protection authority

You have a right to lodge a complaint with the relevant supervisory authority (in particular in the Member State of your habitual residence, place of work or place of the alleged infringement), if you are of the opinion that any of your Personal Data is processed in a manner constituting an infringement of the EU General Data Protection Regulation n°2016 / 679 dated 27 April 2016.

 

d. Our Data Protection Officer (DPO) contact details

You can contact our Data Protection Officer (DPO) at the following address:

 

Email: DPO-Europe@coca-cola.com

 

Street address: Data Protection Officer

Coca-Cola Italia Srl

Viale T.Edison 110/B

 

 

10. How long do we keep your Personal Data?

 

a. We intend to keep your Personal Data accurate and up-to-date. We will delete the Personal Data that we hold about you when we no longer need it.

b. We keep your Personal Data that we use for the purposes described in this Privacy Notice for a period of 2 years maximum, except where legal requirements imposing that we keep your Personal Data longer or less longer apply.

c. To know how long we keep cookies in your terminal equipment, please refer to our Cookie Policy

 

11. Use of Sites by minors and warning for the parents

 

a. The Sites are directed to individuals who are 13 years and above with parents’ consent until 16 years old. We request that other individuals under 13 do not provide Personal Data through the Sites.   We reserve the right to request evidence of parental consent at any time to permit the processing of Personal Data relating to minors.

b. For some Sites, there may be age restrictions, based on what is appropriate viewing for certain ages or what is legally permitted by law.  Where specific age restrictions apply, it will be clearly marked on the relevant Site and we may ask questions to verify your age before proceeding.

 

 

12. What transfers of Personal Data outside the European Economic Area do we carry out?

 

To achieve the purposes described in this Privacy Notice, we transfer your Personal Data to countries outside the European Economic Area ("Third countries") that are deemed to ensure an adequate level of protection under article 45 of the GDPR.

We may also transfer your Personal Data to Third countries that do not ensure an adequate level of protection. In that case, our data transfers are subject to the following appropriate safeguards in accordance with the GDPR, to guarantee that your Personal Data are adequately protected:

- Standard data protection clauses adopted by the EU Commission under article 46 paragraph 2 of the GDPR (click here to access the EU Commission's decision on standard contractual clauses for transfers to processors established in Third countries); and

- EU-U.S. Privacy Shield for transfers to entities located in the United States (click here to access to the EU Commission's decision pertaining to the EU-U.S. Privacy Shield).

To obtain any relevant information regarding any transfers of your Personal Data to Third countries (including the relevant transfer mechanisms), please contact us at this address set out below:

· You can send us an email to the following address: [gbcic@coca-cola.com]

· You can call us on: 0800-227711

· You can write to the following postal address:

Consumer Interaction Center
PO Box 73229
LONDON
E14 1RP]

 

 

13. Applicable law

 

This Privacy Notice is governed by and shall be construed in accordance with the laws of Belgium and any other mandatory provisions of applicable laws in the European Union.

 

 

14. Updates to this Privacy Notice 

 

a. You can find out when this Privacy Notice was last amended by checking "LAST REVISED" at the top of this page.

b. All considered changes to this Privacy Notice will be communicated to you well in advance of the changes actually taking effect.

 

You may print, download or otherwise retain a copy of this Privacy Notice (and of any revised version) for your records.