Coca-Cola Privacy Policy

1. Privacy Statement

The Coca-Cola Company and its affiliates (also collectively referred to as “we”. “our” and “us”) are concerned about privacy issues and want you to be familiar with how we collect, use and disclose information.  This Privacy Policy describes our practices in connection with information that we collect through activities that link to this Privacy Policy including websites (our “Websites”) and any mobile sites, applications, widgets, and other mobile interactive features (collectively, our “Apps”) and other services that we may offer in connections with our Websites and Apps such as rewards programmes, through our official social media pages that we control (our “Social Media Pages”) as well as through HTML-formatted email messages that we send to you  (all collectively, including the Social Media Pages, Apps and Websites, the “Sites”).  

You will have the opportunity to take notice of this Privacy Policy during the registration-process for the Sites and after registration over our Websites. By providing Personal Information to us,  knowing our Privacy Policy you are indicating to agree to the terms and conditions of this Policy.

NV Coca-Cola Services SA, with registered office at Chaussée de Mons 1424, 1070 Brussels and European Refreshments (trading as Coca-Cola Ireland) with registered office at Southgate, Dublin Road, Drogheda, Co Meath. Company Number IE403110. are the legal controllers of the personal data you are providing to us. 

Subject to Applicable Data Privacy Law and wherever required, appropriate local Data Sharing Agreements, We may also grant access to your Personal Information to our local Bottler, e.g. Coca-Cola Enterprises with registered office at Enterprises House, Bakers Road, Uxbridge, Middlesex, UB8 1EZ, or its legal successor in case of structure change, in relation to marketing activities and/or communication about The Coca-Cola Company products and/or promotions.
 

2. Definitions

a. “Personal Information” is information relating to an identified or identifiable individual, such as: 

• Name,

• User name,

• Postal address (including billing and shipping addresses),

• Telephone number (including home and mobile phone numbers),

• Email address, 

• Credit and debit card number,

• Profile picture,

• Social media account ID (such as your Facebook username),

• Location Information, if the Location Information are related to an identifiable individual.

• Personal characteristics

• Hobbies and interests

• Consumption habits

An identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity.

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

• racial or ethnic origin, 

• political opinions, 

• religion or other beliefs, 

• health or medical condition, 

• criminal background, or 

• or trade union membership

• sexual orientation

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

c. “Other Information” is any information that does not reveal your specific identity and does not allow a subsequent identification of the individual, such as: 

• Browser and device information

• Server log file information

• Information collected through cookies, pixel tags and other technologies, provided that a subsequent identification of the user is excluded 

• App usage data

• Demographic information and other information provided by you

• Aggregated information

d. Other People’s Personal Information

You must not submit any Personal Information relating to other people to us or to our service providers in connection with the Sites.  Instead, you must ensure those other people submit their own Personal Information to us directly, including for example by using this Site alongside you.  If – despite this warning – you do submit Personal Information relating to other people to us through this Site - we will take this to mean that you represent that you have their prior authority and explicit consent to do so, including in order for us to use their Personal Information in accordance with this Privacy Policy.

 

3. How We May Collect Personal Information

Subject to the Applicable Data Privacy Law and, where relevant, your consent, we and our service providers (which may act on behalf of our company) may collect Personal Information in a variety of ways, including:  

Through the Sites:  We may collect Personal Information through the Sites, e.g., when you sign up for a newsletter, download an App, set up a rewards account or make a purchase.

Through your use of an App.  When you download and use an App, we and our service providers may 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.

From you when you volunteer it:  Information such as date of birth, gender and zip code, as well as other information, such as your preferred means of communication, may be collected when you voluntarily provide this information.  However, in cases where the same cannot be combined with Personal Information in a way which does or may identify you, this information will not be your Personal Information and our processing of it would not be governed by applicable data privacy law or subject to the relevant sections of this Privacy Policy.  (In all other cases this information will be your Personal Information and it will be governed by applicable data privacy law and it will be subject to the relevant sections of this Privacy Policy).

Physical Location:  We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.

Offline: We may collect Personal Information from you offline, such as when you contact customer service.  In this case we will point you towards this Privacy Policy at that time.  

From Other Sources:  We may receive your Personal Information from other sources, such as public databases; joint marketing partners; social media platforms; from people with whom you are friends or otherwise connected on social media platforms, as well as from other third parties, subject to applicable data privacy law and, where relevant, your consent,. For example if you elect to connect your social media account to your Website/App account or other account that you have created in connection with our services, certain Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your profile or your friends’ profiles.  

Subject to applicable data privacy law, and, where relevant, your consent, the Personal Information you provide through the Sites may be combined with Personal Information and Other Information that you provide to us (via online or offline means), that is publicly available, or that we may otherwise obtain online or offline.

 

4. How We May Use Personal Information

Subject to section 6 below, the Applicable Data Privacy Law and, where relevant, your consent, we may use Personal Information for the following purposes (this is not a definitive list): 

• to respond to your inquiries and fulfill your requests, such as to send you newsletters or to  respond to your questions and comments.

• to send administrative information to you, for example, information regarding the Sites and changes to our terms, conditions, and policies.  Because this information may be important to your use of the Sites, you may not opt-out of receiving these communications.

• to complete and fulfill your purchase and/or your donation, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase and provide you with related customer service.

• to provide you with updates and announcements concerning our products and/or services, promotions and programs and to send you invitations to participate in special programs and for direct marketing purposes, 

• to re-contact you if we have not heard from you in a while, 

• to send you advertising/promotional material from any of our affiliates, and from our promotional and strategic partners. 

• to personalize your experience on the Sites by presenting products, services  and offers tailored to you on the basis of the personal data you have provided to us.

• to process rewards, prizes, and donations, as applicable.  

• to allow you to participate in polls, sweepstakes, instant win promotions, contests and other promotions and to administer these activities.  Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal Information, so it is important that you read the additional rules carefully.

• to allow you to contact and be contacted by other users through the Sites, as permitted by the applicable Site.

• to permit you to participate on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including our Social Media Pages).  

• to permit you to participate in social sharing, including live social media feeds.  

• for our business purposes, such as analyzing and managing our businesses, internal business management and forecasting, market research, audits, developing new products and services, enhancing our Sites, improving our services and products, identifying usage trends, determining the effectiveness of our promotional campaigns, tailoring the Sites experience and content based on your past activities on the Sites, and gauging customer satisfaction and providing customer service (including troubleshooting in connection with customer issues).  

• as we believe to be necessary or appropriate: (a) under applicable law, which may include  laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities which may include public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. 

 

5. How Personal Information May Be Disclosed

Subject to section 6 below, ApplicableData Privacy Law and, where relevant, your consent, your Personal Information may be disclosed to the following recipients (this is not a definitive list):

• to our affiliates (i.e. our group companies) for the purposes described in this Privacy Policy.  

• to our third party service providers and to our affiliates, as relevant, who provide services such as website hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT and marketing services, customer service, email delivery services, credit card processing, auditing services and other similar services to enable them to provide services.

• with our third-party strategic partners with whom we may enter into a special relationship.  Because these third parties will use your Personal Information in accordance with their own privacy practices, you should check their websites for information regarding their privacy practices.

• in connection with promotions, for example, to third parties that are sponsors of sweepstakes, instant win promotions, contests and other promotions, to provide lists of the names and countries of residence of winners and/or to announce the names of visitors on the Sites (e.g., on our blog) or otherwise in accordance with the rules applicable to the applicable promotion.    To the extent that the terms and conditions of the rules concerning the treatment of your Personal Information conflict with this Privacy Policy, the terms and conditions of the rules shall control.

• to identify you to anyone to whom you send messages through the Sites.

• to a third party in the event of 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).

• as we believe to be necessary or appropriate: (a) under applicable law, which may include  laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities which may include public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain. 

 

6. How Personal Information May be used and disclosed in connection with Social Media Services

Subject to Applicable Data Privacy Law and, where relevant, your consent, your Personal Information may be used and disclosed in connection with social media services to the following recipients (this is not a definitive list):

• by you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including our Social Media Pages).  Please note that any information you post or disclose through these services will become public information, and may be available to visitors to the Sites and to the general public.  We urge you to be very careful when deciding to disclose your Personal Information, or any other information, on the Sites.

• if you participate in social sharing (such as if you connect your social media account to your Site account or log-into your Site account from you social media account), to your friends associated with your social media account, to other website users and as well as to your social media account provider, in connection with your social sharing activity.  For example, if you register on the Sites using a social media account, we may post a generic registration message on your social media profile, and if you click a social media “like” button on a Site while logged in to your social media account, your actions may be transmitted to the applicable social media provider and may be available on your social media profile.  By connecting your Site account and your social media account you authorize us to share information with your social media account provider and you understand that the use of the information we share will be governed by the social media site’s privacy policy.  If you do not want your Personal Information shared with other users or with your social media account provider, please do not connect your social media account with your Site account and do not participate in social sharing on the Site. 

• by you, if you participate in a live social media feed (which you may do, for example, by referencing us in your social media post or “liking” us on a social media platform).  If you do participate, your public username and profile photo may be displayed on the Sites along with your post, to the extent permitted by  Applicable Data Privacy Law.  

 

7. How we Use Personal Information For Marketing Purposes

Subject to your consent if required by Applicable Law, we may use Personal Information to provide you with direct marketing about our products and/or services, those of our affiliates or partners, and certain other marketing materials which we believe may be of interest to you. This communication may occur by (without limitation) email, telephone, post, push notifications or SMS.  On the relevant page(s) of this Site, as relevant, there will be consent mechanisms relating to these types of communications, as relevant and if required by Applicable Law. Please note that you may revoke a given consent at any time with future effect in part or in total using the contact information provided in section 19.

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes.  

• If at any time you wish to stop receiving email marketing communications from us, please just let us know by emailing, calling or writing to us using the contact information listed below in the “Contacting Us” section or by using the unsubscribe feature in the respective communication. For example, in emails we may provide you with an ‘unsubscribe’ link, or an email address to which you can send an opt-out request. In your request, where applicable, please indicate that you wish to stop receiving email marketing communications from us.  

• In addition, we will not disclose your Personal Information to third parties, including our subsidiaries, for the third party's direct marketing purposes exempt we have your explicit consent to such transfer and use of Personal Information. 

Please note that changes may not be effective immediately.  We will endeavor to comply with your request(s) as soon as reasonably practicable. In such cases we would not necessarily remove all your Personal Information from our database(s) but we would take steps to seek to note and respect your changed preferences. Please also note that if you do opt-out of receiving marketing-related messages from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

 

8. How We May Collect Other Information

We and our third party service providers may collect Other Information in a variety of ways, including:  

Through your browser or device:  Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, service provider, and the name and version of the Sites (such as the App) you are using.  We use this information only for statistical purposes as well as to ensure that the Sites function properly.  

Through server log files:  Your “IP Address” is a number that is automatically assigned to the computer or device that you are using by your Internet Service Provider (ISP).  An IP Address is identified and logged automatically in our server log files whenever a user visits the Sites, along with the time of the visit and the page(s) that were visited.  Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites.  We use IP Addresses for purposes such as calculating Sites usage levels, helping diagnose server problems, and administering the Sites.  Please note that we treat IP Addresses, server log files and related information as Other Information, except where we are required to do otherwise under applicable law.

Using cookies:  Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes.  We use cookies and other technologies to, among other things, better serve you with more tailored information and facilitate your ongoing access to and use of the Sites.  If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies.  To learn more about cookies, please visit http://www.allaboutcookies.org/.  To learn more about our use of cookies in the EU, please see our cookies policy 

Using Adobe Flash technology (including Flash Local Stored Objects (“Flash LSOs”)) and other similar technologies:  We may use Flash LSOs and other technologies to, among other things, collect and store information about your use of the Sites.  If you do not want Flash LSOs stored on your computer or device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained using the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash LSOs (referred to "information" on the Macromedia site), how to prevent Flash LSOs from being placed on your computer or device without you being asked, and (for Flash Player 8 and later) how to block Flash LSOs that are not being delivered by the operator of the page you are on at the time).  Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with the Sites or our online content.

Using pixel tags, web beacons, clear GIFs or other similar technologies:  These may be used in connection with some Sites pages and HTML-formatted email messages to, among other things, track the actions of Sites users and email recipients, measure the success of our marketing campaigns and compile statistics about Sites usage and response rates.  

By aggregating information:  Aggregated Personal Information does not personally identify you or any other user of the Sites, (for example, we may use Personal Information to calculate the percentage of our users who have a particular telephone area code).  That Aggregated Personal Information may also be used for statistical analysis and administration, including analysis of trends, carrying out actuarial work, tailoring products and services, risk assessment and analysis of costs and charges in relation to our products and services.

 

9. How We May Use and Disclose Other Information 

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under Applicable Law including where such use is not in accordance with Applicable Data Privacy Law.  If we are required to treat Other Information as Personal Information under applicable law, then, in addition to the uses listed in the “How We May Collect Other Information” section above, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.

In some instances, we may combine Other Information with Personal Information (such as combining your name with your zip code).  If we combine any Other Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.

 

10. Third Party Sites / Third Party Service Provider

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other 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 may contain a link to e-commerce websites, including some e-commerce websites that are Coca-Cola branded.  This Privacy Policy does not govern any e-commerce websites to which the Sites may contain a link.  Any Personal Information that you provide through the e-commerce website will be subject to the privacy policy of the e-commerce site, and not this Privacy Policy.  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 Information may be collected by this third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy.  We have no control over, and are not responsible for, this third party’s use or disclosure of your Personal Information 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.  

Additionally, we may provide you with access to third-party functionality that permits you to post content to your social media account(s).  Please note that any information that you provide through use of this functionality is governed by the applicable third party’s privacy policy, and not by this Privacy Policy.  We have no control over, and shall not be responsible for, any third party’s use of information that you provide through use of this functionality.

We are also not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.  

 

11. 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 Information about you that we have previously collected, subject to applicable law and, where relevant, your consent.  Such combined information will be treated as Personal Information hereunder as long as it is so combined.

Subject to applicable law and, where relevant, your consent, 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 this and other websites 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.  

 

12. Technical and Operational Security Measures

We use reasonable organizational, technical and administrative measures to seek to protect Personal Information under our control and as may be required in accordance with applicable data privacy law.  Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below (note that physical mail notification will delay the time it takes for us to respond to the problem).

 

13.1. Exercise of the rights of opposition and revocation of consent to receive commercial communications by electronic means:

You have the right to oppose the processing of your data to receive commercial communications and, at any time, to revoke your consent thereto, in either case (opposition and revocation) with the simple notification to European Refreshments (trading as Coca-Cola Ireland) and Coca-Cola Services nv. To do this, you can apply in any case suppressing the reception of commercial communications by writing to European Refreshments (trading as Coca-Cola Ireland) with registered office at Southgate, Dublin Road, Drogheda, Co Meath indicating your opposition or revocation.

Any such communications will be taken into account by European Refreshments (trading as Coca-Cola Ireland) and Coca-Cola Services nv to ensure your rights under the law on electronic commerce and commercial communications. To that effect, your data may be communicated between these entities.

You can also revoke your consent to receive commercial communications by e-mail upon receipt of the email .

13.2. Exercise of the rights of opposition, access, rectification and deletion of data:

European Refreshments (trading as Coca-Cola Ireland) and Coca-Cola Services nv inform you of the possibility to exercise your rights to access, rectify, cancel and oppose by written request addressed to European Refreshments (trading as Coca-Cola Ireland) and Coca-Cola Services nv at the following address: 38/39 Lower Baggot Street Dublin, Dublin 2.

Your request will be taken into account by European Refreshments (trading as Coca-Cola Ireland) and Coca-Cola Services nv to ensure the exercise of your rights in the files for which each entity is responsible. To that effect, your personal data and request that you exercise may be communicated between these entities.

14. Retention Period

We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.  

 

15. Use of Sites by MINORS and Warning for the Parents

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

For some Sites or App there may be age restrictions, based on what is appropriate viewing for certain ages or what is legally permitted by law.  Where age restrictions apply, it will be clearly marked on the Coca-Cola digital platform and you may be asked to verify your age before proceeding.

Parents should be aware that any Personal Information voluntary provided by their child(ren) or any other person in chats, forums, emails exchanges or any other way of communication offered on the Sites and/or App may result in unsolicited messages, emails or contacts from other parties. Coca-Cola encourages parents to educate their child(ren) to use Internet in a responsible and secure way.


16. Cross border transfer

To the extent permitted under Applicable Data Privacy Law and after fulfilling all relevant conditions for storage and/or transfer of personal data, your Personal Information may be stored and processed in any country where we have facilities or service providers. These countries may provide for different data protection rules than your country.  We may at our discretion and where required by Applicable Data Privacy Law ask you for express consent to transfers of your Personal Information on relevant pages of this Site, including for example by asking you to tick a box to indicate your express consent to the same.

European Union based users should note that their Personal Information will be transferred to countries or territories outside the European Economic Area. In that case, we will ensure that appropriate safeguards based on EU standards (eg contractual arrangements) are put in place to adequately protect your Personal Information  


18. Applicable Law

Wherever this Privacy Policy refers to Applicable Law and Applicable Data Privacy Law, Belgian Law and Irish Law apply.


19. Updates to this Privacy Policy

We may change this Privacy Policy from time to time, including substantive changes to the Cookies we use. We will require your consent on those updates when you login to your account. If you don’t accept the changes you will not be in a position to further login. 

20. Contacting Us

If you have any questions about this Privacy Policy, please contact us as follows:

1. You may call us at:

a. Northern Ireland: 0800 279 9625; or

b. Republic of Ireland: 1-800-936-677

2. You may send mail to the following postal mail address:

Attn: Coca-Cola Ireland

38/39 Lower Baggot Street

Dublin

Dublin 2

 

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

 

Copyright 2016 The Coca-Cola Company. All rights reserved.