Innovinity Privacy Policy | The Coca-Cola Company

Privacy notice for [Insert]

[company name] trading as [insert] (we or us) is a company registered in England and Wales under company number [insert]. Our registered office is at [insert].

Our contact details are [insert email]

[company name] is part of the [Group].

What is the purpose of this document?
1. We are committed to protecting and respecting your privacy. This privacy notice sets out the basis on which any personal data we collect about users of our website at [www.insert] (our site) and how that information will be processed by us.
2. This privacy notice applies to: visitors to our site who do not register as well as those who do; any customers that purchase our goods and/or services from us via our site or otherwise; and all individual contractors and service providers who provide services to our business (you).
3. Cocacola.co.uk is a data controller. This means that we are responsible for deciding how we hold and use personal information about you, and for explaining this clearly to you.
4. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the using the details set out above.
5. Please read this privacy notice carefully to understand what we do with your personal information and what rights you have in relation to our activities.
What is personal data and our lawful basis for processing
1. Personal data, or personal information, means any information relating to an individual from which that person can be identified. There are special categories of more sensitive personal information which require a higher level of protection (see further at section 3.4, below).
2. We will only use your personal information when the law allows us to. Our principle lawful basis for processing is set out in the table below. However, some of our grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
3. We may only rely on our legitimate interests (or those of a third party) to process your personal information, if your interests and fundamental rights do not override those interests. Where we rely on legitimate interests for our processing, we have set out the relevant interest, below.
4. Generally, we do not rely on consent as a legal basis for processing your personal data although, if you are a private individual, we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
5. We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
6. Please note that we may process your personal information without your knowledge or consent where this is required or permitted by law.
7. Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Data we collect about you
1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
  
  Identity Data includes first name, last name, username, date of birth and gender.
  
  Contact Data includes billing address, postal or delivery address, email address and telephone numbers.
  
  Technical Data includes internet protocol (IP) address MAC address, Google Ad ID, Apple Ad ID, your login and engagement data to include date and time of activity on sites number of site visits, location data browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  
  Public Social Network Profile Data includes name, aliases, photos, likes, locations and user created content on social networks such as texts, videos, symbols, hashtags and recordings information about your hobbies and interests.
  
  Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Technical Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
4. As part of our usual course of business, we do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. However, we may process information:
  1. relating to a health condition or disability in order to meet our legal obligation to make reasonable adjustments in the provision of our services;
  2. where it is necessary to establish, exercise or defend a legal claim;
  3. where you have manifestly made the information public; or
  4. otherwise with your explicit consent.
How is your personal data collected?
1. We use different methods to collect data from and about you including through:
2. Direct interactions. You may give us your Identity and Contact Data by filling in forms on the site or by corresponding with us on the site or to customer services. This includes personal data you provide when you:
  1. use our website;
  2. create an account on our website;
  3. request marketing to be sent to you;
  4. enter a competition, promotion or survey; or
  5. give us feedback, make a complaint or contact us.
3. We collect Identity, Contact, Public Social Network Profile Data and Technical Data from our Social Media accounts.
4. Automated technologies or interactions. As you interact with our website or open marketing emails, we will automatically collect Technical Data about your equipment, location, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see section 10, below, for further details.
Children: The Site is intended for individuals aged 13 and over, subject to parental consent up to the age of 16. We ask that individuals under the age of 13 do not provide any personal data via the Site. We reserve the right to request proof of parental consent at any time in order to allow the processing of personal data relating to minors
1. Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below
  1. Technical Data from the following parties:
    - analytics providers such as Google based outside the UK and EU;
  2. Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as [NAME] based [inside OR outside] the EU.

Purposes for which we will use your personal data

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To respond to your requests, questions and comments

(a) Identity Data

(b) Contact Data

Necessary for our legitimate interests (to assist customers and provide responses)

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity Data

(b) Contact Data

(d) Transaction Data

(e) Marketing and Communications Data

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity Data

(b) Contact Data

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity Data

(b) Contact Data

(d) Usage Data

(e) Marketing and Communications Data

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity Data

(b) Contact Data

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity Data

(b) Contact Data

(d) Usage Data

(e) Marketing and Communications Data

(f) Technical Data

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical Data

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity Data

(b) Contact Data

(e) Public Social Media Profile Data

(f) Marketing and Communications Data

Necessary for our legitimate interests (to develop our products/services and grow our business)

Automated decision-making
1. Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention.
2. We use Google's User ID feature to analyse your activity on the site and social media profiles and shared content.
3. This profiling has no legal effect on you, and does not affect your Site experience. It does not involve any monitoring or monitoring of your behaviour or actions. It only allows us to know the preferences and behaviors of Site users in general, and from this analysis, to improve the Sites, as well as our products and services
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
1. We may use your Identity, Contact, Technical and Public Social Media Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
2. You will receive marketing communications from us if you have requested information from us or purchased products from us and you have not opted out of receiving that marketing.
Opting out
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Sharing your information
1. We share your personal information with third party contractors and service providers to the extent necessary to fulfil your order.
2. We share your information with other third parties as follows:
  1. Coca-Cola Services
  2. our regulators, professional advisors, insurance provider and auditors;
  3. Amazon Web Services, that hosts Magento e-commerce solution used for this website and the associated databases;
  4. Adobe for the purpose of personalising adverts that appear on third party websites;
  5. Innovinity and its suppliers, who operate the sale of bottles and cabinets on the site. Data provided to Innovinity is processed in accordance with Innovinity's privacy notice which is available here.
  6. CCA International, which operates the consumer relations center for The Coca-Cola Company's brands in France
  7. if we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets;
  8. payment service providers when you purchase products via the website;
  9. if we have a legal obligation to do so; and
  10. for the purposes of fraud protection and credit risk reduction.
3. The categories of third parties listed above use your personal data for their own purposes and are responsible for their own compliance with data protection legislation.
4. We also share your data with third-party service providers who provide services to our business, such as our website host server, IT support and maintenance service, cloud storage provider and email exchange server, delivery services and other businesses that provide certain services on our behalf. All of our third-party service providers are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third-party service providers to use your personal data for their own purposes.
5. Our online and email advertising service providers may use embedded pixels also known as "spy pixels," "web tags," "invisible GIFs" or similar technologies as part of the Site to help us manage our online and email advertising campaigns, and to improve their effectiveness. For example, if a cookie is placed on your computer by a service provider, the service provider may use spy pixels, web tags, invisible GIFs or similar technologies to recognize the cookie during your visits to the Site and to find out which of our online advertisements are likely to bring you to our Site, and the service provider may be required to share that other information with us for us to use. Please note that we may associate the other information provided to us by our service providers with the Personal Data about you previously collected by us.
Data security
1. We have put in place:
  1. Appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
  2. Procedures to deal with any suspected data security breach, and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
2. Transferring information outside the EEA
  1. We may transfer your Personal Data to countries outside the European Economic Area such as the United States (the "Third Countries"), which are deemed not to guarantee an "adequate level of protection" under Article 45 of the GDPR.
  2. In this case, our data transfers will be subject to Standard data protection clauses adopted by the European Commission under Article 46 paragraph 2 of the GDPR (click here to access the European Commission's decision on standard contractual clauses for transfers to subcontractors based in Third Countries).
  3. In order to obtain any relevant information regarding any transfers of your personal data to Third Countries (including the corresponding transfer mechanisms), you can contact our Data Protection Delegate at:
  4. EU Data Protection Officer - Coca-Cola. Viale T. Edison 110/B - Sesto San Giovanni (MI), Italy and privacy@coca-cola.com
  5. If you are based outside the EEA we may transfer personal information to the correspondence address you provide to us to the extent necessary to complete your order. We will take all reasonable steps to ensure that such transfers are secure. By instructing us from outside the EEA you agree that such transfer is necessary for us to complete your order.
How long will we keep your personal information for?
1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
2. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
3. We keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for two years after they cease being customers for tax purposes and for the purpose of any legal claims.
4. In some circumstances you can ask us to delete your data: see your rights below for further information.
5. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Your rights
1. You have the following rights:
  1. to be told what we are doing with your personal information. We do this by providing you with this privacy notice;
  2. to correct or update the personal information we hold about you.
  3. to object to the processing of your personal information;
  4. to request a copy of the personal information we hold about you;
  5. to ask us to delete the information that we hold about you where there is no good reason for us continuing to process it;
  6. to ask us to stop processing your personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground and where there is no good reason for us continuing to process it;
  7. to ask us to restrict how we use your personal information for a period of time if you claim that it is inaccurate and we want to verify the position or in some limited other circumstances;
  8. to ask us to send your personal information to another organisation in a computer-readable format;
  9. to complain to the Information Commissioner's office if you are unhappy with our use of your personal data: you can do this at https://ico.org.uk/concerns/. Do contact us straight away if you consider that we are not handling your personal information properly so we can try and sort the problem out.
2. If we delete your personal information or restrict our use of it, we will not be able to provide our services to you.
3. If you want to exercise any of your rights, please contact privacy@coca-cola.com. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).
Cookie policy
1. Our website uses cookies to distinguish you from other users of our website. We use cookies for our legitimate interests, to help us to provide you with a good experience when you browse our website and to improve our site. You can view our Cookies Policy on our Site.
Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Last Updated November 2020