CCEAP Consumer Marketing Campaign Privacy Notice
Last revision date:
Coca-Cola Europacific Aboitiz Philippines Inc. and its subsidiaries and affiliates (“CCEAP”, “we”) are committed to respecting your privacy and to manage your personal data fairly and safely. With this Privacy Notice, we would like to inform you why and how we may process your personal data when you participate in one of our marketing campaigns. For more information about CCEAP and our general privacy notice, please visit our website www.cocacolaep.com or refer to the Contact us section below.
The entity responsible for the processing of data relating to the marketing campaign carried out in the Philippines is Coca-Cola Europacific Aboitiz Philippines, Inc. whose head office is located 28th and 29th Floors, Uptown Eastgate, 11th Avenue corner 36th Street, Bonifacio Global City, Taguig City (hereinafter, “CCEAP” or “we”). Our main business is bottling, selling and marketing Coca-Cola products.
- Personal data we collect
- Purposes and legal grounds
- How we disclose Personal Data
- International data transfers
- Retention periods
- Your rights and choices
- Changes to this Privacy notice
- Contact us
Personal data we collect
We may collect personal data in connection with the performance of any activity that is part of our operations. We may collect or obtain this data because you provide it to us (for example via a form), because other people provide it to us (for example, your employer or third-party service providers we use to assist us in our operations) or because they are public.
When we obtain personal data about you through other parties, we make reasonable efforts to include clauses in our contract with those parties, requiring that they comply with the privacy laws and regulations. This may include, for example, requirement to provide you with adequate privacy notice and obtain the necessary consent so that we may process this information in the manner described in this Privacy Notice.
We may also collect or obtain personal data from you, as we observe or deduct such data about you in the way you interact with us or other parties.
In this Privacy Notice, “Personal Data” refers to any information relating to an identified or identifiable individual. For example, your personal data includes your name, email address, IP address, and phone number. We may collect the following personal data:
- First Name
- Last Name
- Mobile Number
- Address
- City
- Email Address
- Sex
- Store Number
- Receipt Number
Contact information, such as your name, address, telephone number, e-mail address (private or business), country of residence.
Correspondence, such as the content, date and time of emails, chats, social media messages and other communications with you, as well as details of your preferences for interactions with us and similar information.
Personal characteristics such as your age, gender, date of birth, place of birth, marital status and nationality.
Transaction information, such as your purchases, customer account data, order and contract data, delivery data, billing and financial data, and transaction history.
Cookies are small data files that are placed on your computer or mobile device when you visit a website or use an online service. We may use cookies and similar technologies on our sites and other services. For more information about our use of cookies, please see our Cookie Policy at Coca-Cola Europacific Aboitiz Philippines (CCEAP) www.cocacolaep.com or the information provided on the site visited.
Where applicable, we indicate whether and why you must provide us with your personal data, as well as the consequences of failing to do so. For example, if certain personal data is necessary to provide services you have requested, or if we are legally required to collect it, and you decline to provide us with that personal data, then we cannot provide you with the services you have requested.
Purposes and legal grounds
We use your data for the following purposes:
Participation in our campaigns: To enable you to participate in our marketing campaigns and to provide you with all the related services.
Communication with you: To respond to your requests and comments, to provide you with the information you have requested.
Marketing: For marketing and market research purposes, such as contacting you with our newsletters, surveys and other marketing or promotional materials, analyzing and maintaining our activities, internal management, and forecasting, auditing, developing new products, improving our websites, products and services, identifying trends, conducting market research, evaluate the effectiveness of our marketing campaigns, measuring customer satisfaction and improving customer service.
We only process your personal data based on a valid legal ground, including when:
- You have consented to the use of your personal data, for example when you consent to receive marketing communications from us;
- We need your personal data to enter into, or perform an agreement with you, for example to process orders or participate in a promotional campaign;
- We have a legal obligation to use your personal data, for example to comply with tax and accounting obligations;
- We have a legitimate interest in using your personal data. For example, CCEP has a legitimate interest in using your personal data to conduct market research, product development and internal analytics, and otherwise to improve the safety, security and performance of our services. We only rely on our or a third party’s legitimate interests to process your personal data when these interests are not overridden by your rights and interests.
How we disclose Personal Data
We may disclose information to third parties with your consent, as well as in the following circumstances:
CCEP Group companies. We may disclose your personal data about you to other members of the CCEP Group of companies.
Service providers. We may disclose your personal data to third party service providers who provide us with application development, hosting, maintenance, and other services. These third parties may have access to or process personal data about you as part of providing those services for us. We limit the personal data provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.
Business partners. We may disclose your personal data to partners like customers, brand owners, distributors, joint ventures and others in conducting our business.
Compliance with laws and law enforcement. We may disclose your personal data as required by law or when we believe that disclosure is necessary to protect the security or integrity of our services, or to protect the legitimate interests, rights, property, or safety of CCEP, its employees, users, or others, or to comply with a judicial proceeding, court order, or governmental or regulatory request or any other legal process served on us.
Business transfers. We may disclose personal data to an acquirer, successor, or assignee of our company as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
Advertising partners. With your consent, we may transfer your personal data to third party advertisers or sponsors for direct marketing purposes, including targeted advertising, for example to reach a particular audience.
Aggregated data. We may pass aggregated information to third parties but this will not include information that could be used to identify you.
International data transfers
We may transfer your personal data to recipients in countries outside of the European Union whose laws may not provide the same level of data protection. When we do so, we will ensure that there are adequate safeguards in place to protect your personal data that comply with our legal obligations. The adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal data to third countries.
For more information about the transfers described above and the sufficient guarantees we use to protect these transfers, you can contact us using the contact information below.
Retention periods
We take steps to erase your personal data or to keep it in a form that does not identify you when that information is no longer needed for the purposes for which we process it, unless we are required by law to keep it longer.
When determining the retention period, we take into account several criteria, such as the type of services we provide to you or that you provide us, the nature and duration of our relationship with you, a possible re-registration in our services, the impact on our services if we delete certain information you have provided to us or about you, the mandatory retention periods provided by law and the corresponding limitation period.
When your personal data is collected and processed for the purpose of sending commercial prospections, these are retained for three years from collection, before being permanently deleted unless you contact us again.
When your personal data is collected and processed for specific purposes related to our marketing campaigns, including your participation in the various activations, these will be retained for six months from the end of the activation, before being permanently deleted unless you contact us again.
Your rights and choices
You can contact us at any time for assistance regarding the processing of your personal data. In addition, you have the right at any time to:
- To obtain confirmation that we are processing your personal data and to request a copy of the personal data that we hold about you;
- Request that we update your personal data, or correct any personal data that you believe is incorrect or incomplete;
- To request that we delete your personal data, or that we limit our use of your personal data if you believe that there is no (longer a) a lawful ground for us to process it;
- Withdraw your consent to the processing of your personal data (to the extent such processing is based on consent);
- Receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used, machine-readable format and to transmit such personal data to another party (to the extent that processing is based on consent or a contract);
- Object to our processing of your personal data for which we use a legitimate interest as a legal basis, in which case we will cease the processing unless we have compelling legitimate grounds for the processing; and
- You also have the right to object at any time to the processing of your personal data for direct marketing. If you no longer wish to receive direct marketing from us, you can contact us or click on the unsubscribe link in any such communication.
In order to exercise your rights, you can send us a request, indicating the right you wish to exercise by contacting us as indicating at the bottom of this Privacy Notice. However, there are exceptions and limitations to each of these rights. We may, for example, charge a reasonable fee or refuse to act on a request if it is manifestly unfounded or excessive, in particular because of its repetitive character. In some situations, we may refuse to act or may impose limitations on your rights if, for instance, your request is likely to adversely affect the rights and freedoms of others, prejudice the execution or enforcement of the law, interfere with pending or future litigation, or infringe applicable law. In all cases, you have a right to file a complaint with a data protection authority.
Changes to this Privacy notice
We may modify or amend this Privacy Notice from time to time. Any changes we may make to this Privacy Notice in the future will be posted on this page. To let you know when we make changes to this Privacy Notice, we will amend the revision date at the top of this page. The new modified or amended Privacy Notice will apply from that revision date. Please check back periodically to see changes and additions.
Contact us
If you have any questions about this Privacy Notice or our privacy practices in general, please contact us via our contact form, or via post at:
Email: contactus.ph@ccep.com
SMART/PLDT Toll Free Hotline: 1800-1888-COKE (2653)
GLOBE Toll Free Hotline: 1800-8888-COKE (2653)
You can also contact our Data Protection Officer by e-mail at privacy@ccep.com.
If you have any questions regarding activation in particular, please contact us by email at contactus.ph@ccep.com.
