CCBPI Privacy Notice

Transaction information, such as your purchases, customer account information, order and contract information, delivery details, billing and financial data, creditworthiness, and transaction history.

User-generated content, such as your postings on any blogs, forums, wikis and any other social media applications and services that we provide.

Public information, including information that is available on the Internet, such as social media information, public records, and news reports.

Vendor screening information, such as professional qualifications, licenses and certificates, work permits, government identification documents, potential conflicts of interest, and ultimate beneficial ownership, each as permitted or required by applicable law.

Referral and business leads, such as contact details about referrals and business leads received from business partners.

Stakeholder data, such as information about public authority figures and other stakeholders collected from agencies or public sources.

Website and service usage information, such as the host name and IP address of your device, your browser type and version, your operating system, the pages you visit, the time and duration of your visit, and the website that referred you to us.

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 websites and other services. For example, cookies can be set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks, including Facebook. For more information about our use of cookies, please see our Cookie Notice .

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

We use information held about you for the following purposes:

Providing the services. To operate, maintain, enhance and provide all features of the website and other services.

Communicating with you. To respond to your inquiries and comments, to provide you with information you have requested.

Fulfilling your orders. To fulfil orders for products or services and related activities, such as product and service delivery, customer service, account and billing management, and support and to provide other services related to your orders.

Managing our relationship with you. To manage your ongoing relationship with us, including managing contractual or other obligations, interacting with you, informing you about our products or services, as well as special offers and promotions.

Communications. To contact you for prospective partnership and other business development purposes, or to send related communications, including invitations to CCBPI activities or other social events.

Marketing. For marketing and market research purposes, such as contacting you with our newsletters, surveys and other marketing or promotional materials, analysing and maintaining our activities, internal management, and forecasting, auditing, developing new products, improving our websites, products and services, identifying trends, conducting market research, evaluating the effectiveness of our marketing campaigns, measuring customer satisfaction and improving our customer service.

Vendor screening. To evaluate prospective vendors and business partners to ensure their compliance with applicable legal requirements, industry standards and our policies.

Operating our business. Managing our everyday business needs, such as payment processing and financial account management, product development, contract management, website administration, fulfilment, corporate governance, audit, reporting and legal compliance.

Protecting CCBPI. To ensure the security of our websites, networks and systems, and premises, as well as protecting us against fraud.

Compliance. To comply with applicable legal requirements, industry standards and our policies, to conduct audits and investigations.

Social media accounts

By using our social media accounts, you interact with us, for instance, by subscribing to a fan page, leaving your reaction (like, comments) or sending a message to us. The information you provide us with may constitute personal data. We may process personal data collected through accounts on the social media sites to manage those accounts. For further information on how these social media providers process your personal data, including the legal basis they rely on and the ways to exercise your rights.

Legal grounds

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 our use of cookies on a CCBPI website, or 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 you place;

We have a legal obligation to use your personal data, for example to comply with tax and accounting obligations; or

We have a legitimate interest in using your personal data. For example, CCBPI has a legitimate interest in using personal data to conduct market research, product development, and internal analytics, or to contact public authority figures and other stakeholders in the context of social activities or other types of business events, 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:

CCBPI Group companies. We may disclose personal data about you to other members of the CCBPI 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.

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 CCBPI, 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 the Philippines 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 relevant authorities for transfers of personal data to third countries. For more information about the transfers described above and the adequate safeguards we use to protect such transfers, you may contact us through the contact information set forth below.

Retention periods

We take measures to delete your personal data or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this data for a longer period. When determining the retention period, we take into account various criteria, such as the type of services we provide to you, or that you provide to us, the nature and length of our relationship with you, possible re-enrollment with our services, the impact on our services if we delete some information from or about you, mandatory retention periods provided by law and the relevant statute of limitations.

Your rights and choices

You can contact us at any time for assistance regarding the processing of your personal data. Furthermore, you have the right at any time to:

Obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;

Ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;

Ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data if you believe that there is no (longer a) lawful ground for us to process it;

Withdraw consent to our 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 and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);

Object to our processing of your personal data for which we use 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 have also the right to object at any time to the processing of personal data for direct marketing. If you do not want to continue receiving any direct marketing from us, you can contact us or click on the unsubscribe function 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 (including Addendums) 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.

How to contact us
If you have any queries about this Privacy Notice or our privacy practices in general, you can contact our Data Protection Officer via email at dpo@coca-cola.com.ph.