This Policy
Suntory Beverage & Food Europe (SBFE) is a regional construct which manages the operation of our
European business units
In this policy any reference to the ‘Company’ relates to SBFE Business Unit and includes the following:
Lucozade Ribena Suntory
Lucozade Ribena Suntory Ireland
Orangina Schweppes France
Orangina Schweppes Belgium
Schweppes Suntory Espana
Schweppes Suntory Portugal
Schweppes International Limited
Orangina Schweppes Poland
Citresa
This Privacy Policy explains how we use the personal information that the Company collects or generates both in relation to this website and our products and services.
The list below sets out what is covered in this Privacy Policy and you can click on the headings below to go to a specific section.
1. Background
The Company with its registered office at SBFE EEIG, 40-52 boulevard du Parc 92200 Neuilly sur Seine, France collect and use certain Personal Data. The Company is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.
We respect privacy and we are committed to keeping all your Personal Data secure. This Privacy Policy governs the handling of Personal Data by our Company in the course of carrying on commercial activities.
We use the following definitions in this Privacy Policy:
“Personal Data” means any data which relates to a living individual who can be identified from that data or from that data and other information which is in the possession of, or is likely to come into the possession of, our Company (or its representatives or service providers). In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of the Company or any other person in respect of an individual.
2. The product and services we provide
This Privacy Policy concerns the following categories of information that we collect about you when providing the following products and services:
Information we receive through our websites;
Information we receive through our activities;
Information we receive through the manufacture and the sale of our products.
3. The type of personal data we collect
Many of the activities of our Company require us to obtain Personal Data about you in order to perform the services or obligations we have been engaged to provide. In relation to each of the activities, we will collect and process the following Personal Data about you:
Information that you provide to us. This includes information about you that you provide to us. The kind of Personal Data we might ask for, may include (by way of a non-exhaustive list):
basic Personal Data (such as first name; family name; position in the company; company name; company email address; business phone number; business address; city; postcode; country);
any information that you choose to share on our Internet forums which may be considered Personal Data. (Please note that our Company does not collate information included on our Internet forums together with Personal Data from your User Center account or profile);
Information that we collect or generate about you. This includes (by way of non-exhaustive list):
a file with your contact history to be used for enquiry purposes so that we may ensure that you are satisfied with the services which we have provided to you;
activity data relating to the use of protected documents, such as altering a document’s permissions and information regarding the individual that performed the activity.
Information we obtain from other sources.
Cookies
When you visit our Websites, cookies are used to collect technical information about the services that you use, and how you use them
For more information on the cookies used by us please see our Cookie Policy of the website.
Anonymized data
In addition to the categories of Personal Data described above, we will also process further anonymized information and data that is not processed by reference to a specific individual.
Children
We take children's privacy protection seriously. We operate this website in compliance with all applicable laws in the countries in which we operate business.
Children under 16 years of age should have a parent/guardian's consent before providing any personal information to the website or using any of our products and services. We will not, as provided by applicable law, require or request children under this age to provide more personal information than is reasonably necessary to participate in the applicable activity on the website or participate in our products and services.
If you are under the age as determined by the local age regulation, you will not be able to register in this Website.
Our Company is not responsible for cases in which minor persons have sent all personal data through this website.
4. How we use your information
Your Personal Data may be stored and processed by us in the following ways and for the following purposes:
for ongoing review and improvement of the information provided on our Websites to ensure they are user friendly and to prevent any potential disruptions or cyber-attacks;
to assess your application for our business, where applicable;
to set up customers for our business;
to set up users to use the User Center;
for statistical monitoring and analysis of current attacks on devices and systems and for the on-going adaptation of the solutions provided to secure devices and systems against current attacks;
to understand feedback on our Products or Services and to help provide more information on the use of those Products and Services quickly and easily;
to communicate with you in order to provide you with services or information about our business, our company and our Products;
for in-depth threat analysis;
to understand your needs and interests;
for the management and administration of our business;
in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or
for the administration and maintenance of databases storing Personal Data.
However when we use Personal Data we make sure that the usage complies with applicable law and regulations and the law and regulations allow us and require us to use Personal Data for a variety of reasons. These include:
we need to do so in order to perform our contractual obligations with customers;
we have obtained your consent;
we have legal and regulatory obligations that we have to discharge;
we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings;
the use of your Personal Data as described is necessary for our legitimate business interests, such as:
allowing us to effectively and efficiently manage and administer the operation of our business;
maintaining compliance with internal policies and procedures;
monitoring the use of our copyrighted materials;
enabling quick and easy access to information on our Company, our business and our Products;
offering optimal, up-to-date security solutions for mobile devices and IT systems; and
obtaining further knowledge of current threats to network security in order to update our security solutions and provide these to the market.
We will take steps to ensure that the Personal Data is accessed only by employees of our Company that have a need to do so for the purposes described in this Privacy Policy.
5. Disclosure of your information to third parties
We may share your Personal Data within the Suntory group of companies for the purposes described above:
We may also share your Personal Data outside of the Suntory group for the following purposes:
with our business partners. For example, this could include our partners from whom you or your company or your organisation purchased our Products. Personal Data will only be transferred to a business partner who is contractually obliged to comply with appropriate data protection obligations and the relevant privacy and confidentiality legislation;
with third party agents and contractors for the purposes of providing services to us (for example, the Company’s accountants, professional advisors, IT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Privacy Policy;
to the extent required by law and regulations, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights;
if we sell our business or assets, in which case we may need to disclose your Personal Data to the prospective buyer for due diligence purposes; and
if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer.
6. International transfers of personal data
Our Company is a global business. Our customers and our operations are spread around the world. As a result we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your country.
Where we transfer your Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways:
the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data;
the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data;
where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; or
in other circumstances the law may permit us to otherwise transfer your Personal Data outside Europe.
You can obtain more details of the protection given to your Personal Data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described in paragraph 10 below.
7. How we safeguard your information
We have controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.
As a condition of employment, our employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need it to perform their roles. Unauthorised use or disclosure of confidential SBFE entity information by one of our employees is prohibited and may result in disciplinary measures.
When you contact one of our employees about your file, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.
8. How long we keep your personal data
How long we will hold your Personal Data for will vary and will be determined by the following criteria:
the purpose for which we are using it, for instance the duration of your contract with us – we will need to keep the data for as long as is necessary for that purpose; and
legal obligations – laws or regulations may set a minimum period for which we have to keep your Personal Data.
9. Your rights
In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge.
These rights include:
the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation;
In some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to our Company;
the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
the right to provide us instructions regarding the processing of your personal data after your death.
If you wish to verify, correct, access, update, delete any of your personal information or "opt out" of receiving communications from us as discussed above, please send a request marked as “Data Access Request” to the following:
Email us via:
consumer.care@lrsuntory.com
Write to us via:
Lucozade Ribena Suntory Ltd
2 Longwalk Road,
Stockley Park,
Uxbridge,
United Kingdom,
UB11 1BA
For all other queries regarding your rights you can get in touch by contacting us using the details listed in paragraph 10 below.
10. Questions and concerns
If you have any questions or concerns about us handling of your Personal Data, or about this Policy, please contact our Data Protection Officer using the following contact information:
Email Address:
GDPR.Info@suntory.com
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from our Data Protection Officer, you should, in the first instance, contact your local regulator. In the U.K, the relevant authority is The Information Commissioner’s Office (ICO):
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Tel: 0303 123 1113 (local rate) or 01625 545 745 (national rate)
Because we have offices in several different European locations, we have also registered a Supervising Lead Autority (SLA), Depending on the nature of your concern, the matter may be referred to our SLA:
Commission Nationale de l’Informatique et des Libertés (CNIL)
3 place de Fontenoy
75007
Paris.
Privacy Policy
[COMPANY NAME] ("We") are committed to protecting and respecting your privacy.
This policy (together with our terms of use [INSERT AS LINK TO WEBSITE TERMS OF USE] and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting [URL OF RELEVANT WEBSITE] you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is [COMPANY NAME] of [ADDRESS].
Information we collect from you
We will collect and process the following data about you:
Information you give us. This is any information about you that you give us by filling in forms on our site [INSERT DOMAIN ADDRESS] (our site) or by corresponding with us by phone, e-mail or otherwise.
Information we collect about you. With regard to each of your visits to our site we will automatically collect the following information:
technical information, including [the Internet protocol (IP) address used to connect your computer to the Internet,] [your login information,] [browser type and version,] [time zone setting,] [browser plug-in types and versions,] [operating system and platform,] [OTHER];
information about your visit, including [the full Uniform Resource Locators (URL),] [clickstream to, through and from our site (including date and time),] [pages, items or products you viewed or searched for'] [page response times,] [download errors,] [length of visits to certain pages,] [page interaction information (such as scrolling, clicks, and mouse-overs),] [methods used to browse away from the page,] [OTHER] and any phone number used to call our customer service number.
Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. It may include information provided by anyone who referred you to our websites or services.
Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie policy [LINK].
Uses made of the information
We use information held about you in the following ways:
Information you give to us. We will use this information:
to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products or services that you request from us;
if relevant to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the [order form OR registration form]);
to notify you about changes to our service;
to ensure that content from our site is presented in the most effective manner for you and for your computer.
Information we collect about you. We will use this information:
to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our site safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of your information
You agree that we have the right to share your personal information with:
Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
Selected third parties including:
business partners, suppliers and sub-contractors if required for the performance of any contract we enter into with them or you;
advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we will provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience;
analytics and search engine providers that assist us in the improvement and optimisation of our site;
if relevant to our services, credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
We will disclose your personal information to third parties:
In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
If [COMPANY NAME] or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use [INSERT AS LINK TO WEBSITE'S TERMS OF USE] [or terms and conditions of supply [INSERT AS LINK TO WEBSITE'S TERMS AND CONDITIONS OF SUPPLY OF GOODS AND/OR SERVICES]] and other agreements; or to protect the rights, property, or safety of [COMPANY NAME], our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.]
Where we store your personal data
The data that we collect from you will be transferred to, and stored at, a destination inside the European Economic Area ("EEA"). It will be processed by staff operating inside the EEA who work for us or for one of our suppliers where necessary to provide any services or goods that you have ordered through our website. By submitting your personal data, you agree to this transfer, storing or processing. [COMPANY NAME OR We] will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.]
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted [using SSL technology].] Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at [ADDRESS OR E-MAIL ADDRESS].
Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request will be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
Changes to our privacy policy
Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [ADDRESS OR E-MAIL ADDRESS].
