Welcome to the Coca‑Cola Consumer Privacy Policy

This Privacy Policy also may apply to personal information provided to us by consumers who engage with us through social media.  Please contact us at privacy@coca-cola.com if you have questions about whether this Privacy Policy applies to specific personal information connected with social media. 

This Privacy Policy does not apply to websites and other online services operated by other organizations.  Those other websites and services follow their own privacy policies, not this Privacy Policy.  Please make sure to check those privacy policies so you know how your information is handled.

The personal information that you choose to give to us typically includes the following types of personal information.  Please review below to learn more about the categories of personal information that Coca‑Cola collects and why it is collected:

Contact and Account Information

Coca‑Cola requests your first and last name, email address and/or mobile telephone number and date of birth to create an account on the Services.  We also may collect username and password, age, mailing address, government-issued identifier and similar contact information.

• To maintain your online account if you choose to create one
• To verify identity and eligibility for certain Services
• To customize your experience of the Services
• To offer access to exclusive content, discounts and other opportunities
• To administer a sweepstakes, contest or other promotion or a loyalty program
• To complete a purchase and deliver products 
• To send information that we think will interest you, which is sometimes personalized based on the information associated with your account
• To request your feedback, such as through a survey about a new product
• To respond to your questions and provide customer service
• For research and innovation
• When you attend an in-person event, such as events  sponsored or hosted by Coca‑Cola or product sampling
   

User Generated Content (UGC) 

Coca‑Cola collects the posts, comments, opinions, voice recordings, photos and videos that you choose to submit through the Services

• To monitor online communities 
• To record and act on your comments and opinions, such as in surveys, customer service inquiries and other free-form text boxes
• To administer your participation in promotions that include submission of UGC
• In connection with participation in specific promotions or other Services, such as Coca‑Cola’s smart coolers.

Photos, voice recordings and videos that you choose to share may constitute biometric data under some laws. Coca‑Cola collects biometric data only with your specific consent.

Information associated with an account on a social media platform

When you connect or log into the Services through your social media account, such as Facebook and Twitter, we collect the personal information permitted by the social media platform and your account permissions, such as your profile photo, email, like and interest and friends, followers or similar lists.

• To personalize your experience of the Services
• To respond to your comments and inquiries posted on the social media platform and analyze communications (such as tweets or posts) with or about Coca‑Cola to better understand how consumers view Coca‑Cola

(If you decide later that you do not want to provide us with information from your social media account, then please adjust the privacy settings in your social media account.)
 

Location Data

We collect precise geolocation ( aka GPS) data when permitted through our Apps when you choose to allow it through your mobile device’s operating system and otherwise with your consent, as required.

Approximate location from an IP address or connections to WiFi, Bluetooth or a wireless network service is automatically collected when you use the Services.

We collect this location data:

• To customize your experience of the Services
• To let you know when products, promotions or events are available near you or allow other users to see your location when you choose to allow it
• To send geographically-relevant advertising
   

Other Personal Information shared through the Services

We collect

• To administer our online communities 
• To manage promotions and other features of the Services that allow you to share your personal information

The information that we automatically collect includes:

• information about your computer or mobile device, such as device type and identification number, browser type, internet service provider, mobile network and operating system
• IP address and broad geographic location (e.g., country or city-level location) 
• how a computer or mobile device interacts with the Services, including the date and time the Services are accessed, search requests and results, mouse clicks and movements, specific webpages accessed, links clicked and videos watched
• traffic and usage measurements
• data about the third-party sites or services accessed before interacting with the Services, which is used to make advertising more relevant for users
• interactions with our marketing communications, such as whether and when a Coca‑Cola email is opened

The types of personal information that we receive from third parties are:

• Personal information associated with purchases.  Payment card purchases are processed by third-party payment processors. Coca‑Cola does not have access to complete bank account numbers, credit card numbers or debit card numbers. 
• Personal information that is commercially available from marketing services providers or collected by marketing partners through campaigns and events, which is used to help identify individuals who may be interested in learning more about Coca‑Cola and to supplement personal information we already have.  This personal information includes insights from matching our pseudonymized data sets with third parties’ pseudonymized data sets, including though data clean rooms (see also Section 4 below).
• Personal information that we receive from the third-party advertising partners that help us provide more relevant advertising 
• Personal information shared with Coca‑Cola by bottler partners
• Personal information from publicly-available sources
• Personal information from law enforcement and other government authorities (but only in rare cases)

We may combine information that Coca‑Cola has about you or combine data from third-party data sources.  We require that each third-party data provider confirm that its sharing of personal information with Coca‑Cola is transparent to consumers and otherwise lawful.

We use personal information to provide, personalize and improve the Services (in each case as permitted by applicable law), including:

• To create and update users’ accounts and fulfill users’ requests
• To centralize consumers’ personal information in a database managed by a third party on our behalf and append information collected from third parties
• To send marketing and non-marketing communications to users
• To enable communications among users, such as an online community
• For targeted advertisements (also sometimes referred to as personalized or interest-based advertising) based on information generated by a user’s online activity, such as visiting websites that contain our advertising partners’ ads or cookies, some of which are based on geo-location.  
• To learn more about our users so we can recommend content that we think will interest particular users
  • In particular, we develop insights about users by participating in ‘data clean rooms.’  Through a data clean room, we run queries and extract outputs and insights from data offered by third parties that also participate.  Data used in data clean rooms is shared by other businesses and participants in a format that does not directly reveal or expose personal information; instead, before matching, an identifier is created and used to match the third-party data sets with Coca‑Cola’s pseudonymized personal information. (Using personal information for the purpose of creating pseudonymized data involves prior profiling of data sets.)   After the matching process, we receive aggregated information about our audience that does not allow for enrichment of individual data sets unless we inform you or otherwise obtain separate consent.  Data sharing in data clean rooms is for the purpose of audience discovery, audience expansion, audience targeting and look-alike audience modelling. 
• For promotion and loyalty program administration
• For customer service 
• For facilitating payment
• To analyze how users interact with the Services and activity trends so that we can develop new features and content that meet our consumers’ expectations
• To improve the Services and users’ experience of them
• For data analytics, research, product development and machine learning that enable us to better understand our consumers and offer innovations for them
• For monitoring and testing the Services, including to troubleshoot operational problems
• To create anonymized data, which are not subject to this Privacy Policy, that are used in improving Coca‑Cola’s products and services and similar business purposes and otherwise as permitted by contract and law
• To detect and protect against fraud, abusive and unauthorized use of the Services
• For risk management and similar administrative purposes, such as to monitor and enforce compliance with user agreements and otherwise comply with laws applicable to Coca‑Cola

What are cookies?
Cookies are small text files that are sent to or accessed from your web browser or your computer's hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer or device, such as settings, browsing history and activities conducted while using the Services.

Coca‑Cola also uses “pixels” (sometimes called web beacons). Pixels are transparent images that can collect information about email opens and website usage across websites and over time.

Cookies that Coca‑Cola sets in the Services are called first-party cookies. Cookies set in the Services by any other party are called third-party cookies. Third-party cookies enable third-party features or functionality on or through the Services, such as analytics and marketing automation. The parties that set third-party cookies can recognize your device both when you use it to access the Services and also when you use it to visit certain other websites.  To learn more about cookies generally, visit www.allaboutcookies.org. 

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked.  If a website that responds to a particular DNT signal receives the DNT signal, the browser blocks that website from collecting certain information from the browser cache. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Coca‑Cola, do not yet respond to DNT signals.

Why does Coca‑Cola use cookies and other data collection technology?
Some cookies are required for the Services to operate. Other cookies enable us to track the interests of users for targeted advertising and to enhance the experience of the Services.

The types of cookies served on through the Services and why they are used is as follows:

• Strictly necessary cookies are required for the Services to operate.
• Performance or Analytics cookies collect information about how the Services are used so we can analyze and improve the Services. Performance or analytics cookies typically remain on your computer after you close your browser until you delete them.
• Advertising cookies are used to make advertising messages more relevant to you by helping us display advertisements that are based on your inferred interests, prevent the same ad from appearing too often and ensure that ads are properly displayed for advertisers.
• Social media cookies allow users to interact more easily with social media platforms. We do not control social media cookies and they do not allow us to gain access to your social media accounts without your permission. Please refer to the relevant social media platform’s privacy policy for information about the cookies used.  

Data collection technology enables Coca‑Cola to monitor the traffic patterns from one webpage to another, to deliver or communicate with cookies, to understand whether users visit the Services after seeing our online advertisement displayed on a third-party website, to improve performance of the Services and to measure the success of our email marketing campaigns.  Coca‑Cola’s Cookie Policies (available in certain jurisdictions) describe Coca‑Cola’s use of data collection technology.  

Google Products
Where permitted by applicable law, the Services use Google Analytics for targeted advertising (which Google sometimes refers to as ‘remarketing’).  Google uses cookies that Google recognizes when consumers visit various websites.  The data collected through Google’s cookies helps Coca‑Cola analyze how the Services are used and, for some Services and in some jurisdictions, to personalize marketing communications and digital advertising.

The Services also embed videos from YouTube (a Google company) by framing.  This means that, after you click the button to play a YouTube video through the Services, a connection between the Services and  the YouTube servers is established.  Then, an HTML link provided by YouTube is inserted into the code of the Services to create a playback frame. The video stored on the YouTube servers is then played by the frame in the Services.  YouTube also receives information that informs YouTube that you are currently using the Services: your IP address, browser information, the operating system and settings of the device you are using, the URL of the current web page, previously-visited web pages if you have followed a link, and the videos you watched.  If you are logged into your YouTube account, the information may be associated with your YouTube user profile. You can prevent this association by logging out of your YouTube account before using the Services and deleting the corresponding cookies. 

For more information about how Google collects, uses and shares your information, please visit Google’s Privacy Policy

For more information about how Google uses cookies in advertising, please visit Google’s Advertising page.  

To prevent Google Analytics from using your data, you can install Google’s opt-out browser add-on.  

To opt out of ads on Google that are targeted to your interests, use your Google Ads settings

If you are located in the EEA, Switzerland or UK, please note in particular that, if you allow Google’s cookies in Coca‑Cola’s Privacy Preference Center, the information generated by those cookies about use of the Services is transmitted to and stored by Google on servers in the United States. Coca‑Cola used technology tools, including Google’s IP Anonymization tool, to exclude the last part of your IP address before the data is transferred by Google to the United States, as well as Google’s tools for deactivation of data sharing and Google signals and User-ID settings in Google Analytics for certain jurisdictions.  Google will not associate an IP address with any other data held by Google.  

On behalf of Coca‑Cola, Google will use the data described above to compile reports that help Coca‑Cola operate and provide the Services.

Meta Products
Some part of the Services use products and features offered by Facebook, Instagram and Messenger and Facebook apps (Meta Products).  The Meta Products use tags, pixels (the Meta Pixel) and other unique tracking codes and technology that collect user information (including personal information) from the Services.  Facebook tracks user interactions with the Services after a user clicks on an ad placed on Facebook or other services provided by Meta (called a conversion) and enables Coca‑Cola to learn more about how users engage with ads and similar information.    The Meta Products use the collected data for Meta’s own purposes, including to improve the Meta Products.  Meta may transfer data that it collects from the Services to the USA and other countries, where you may have fewer rights to related to your personal information.  To learn more about how the Meta Products collect, use and process personal information and how you can manage or delete personal information about you, please see the Privacy Policy for the Meta Products at https://www.facebook.com/about/privacy.

Your Cookie Choices
You can set your browser to refuse all cookies or to indicate when a cookie is set. (Most browsers accept cookies automatically but allow you to disable them but note that some features of the Services may not work properly without cookies.)  

As noted above, Google has developed an opt-out browser add-on if you want to opt out of the cookies used for Google Analytics.  You can download and install the add-on for your web browser here.  You may refuse the use of these cookies by selecting the appropriate settings on your browser.  To learn more about how to view and manage your information on the Meta Products, please see here. 

Certain jurisdictions in which the Services are available also have cookie policies which are separate from and supplement this Privacy Policy and tools to manage cookies.  Please refer to Section 9 for details. 

Coca‑Cola shares personal information with the following categories of recipients:

• Professional advisors, such as lawyers, accountants, insurers and information security and forensics experts.
• Marketing vendors that help promote the Services (such as by email marketing) and from time to time supplement personal information that we already have.  For example, Meta receives and uses certain data related to the use of the Services to help us deliver personalized advertising on its platform and assess the effectiveness of this advertising.  
• Service providers to enable them to perform services on our behalf, including data analytics, data security, ecommerce operations, surveys, research, administration of promotions, offers and loyalty programs and otherwise to help us carry out our business.  Some of these service providers have global responsibilities.
• For strategic partnerships, such as with sports leagues and manufacturers and other providers of complementary offerings.
• Through data clean rooms as described in Section 4.  Data sharing in a data clean room is for the purpose of audience discovery, audience expansion, audience targeting and look-alike audience modelling. 
• Cloud storage providers.
• Potential or actual acquirers or investors and their professional advisers in connection with any actual or proposed merger, acquisition or investment in or of all or any part of our business. We will use our best efforts to ensure that the terms of this Privacy Policy apply to personal information after the transaction or that users receive advance notice of changes to personal information processing.
• Coca‑Cola affiliates and bottler partners.
• Competent law enforcement, government regulators and courts when we believe disclosure is necessary (i) to comply with the law, (ii) to exercise, establish or defend legal rights, or (iii) to protect the vital interests of users, business partners, service providers or another third party.
• Other third parties with your permission.

If we share personal information, we require that the recipients handle personal information in compliance with this Privacy Policy and our confidentiality and security requirements.  

Coca‑Cola uses technical, physical, and administrative safeguards intended to protect the personal information that we process. Our safeguards are designed to provide a level of security appropriate to the risk of processing your personal information and include (as applicable) measures to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and a procedure for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing of personal information.  Coca‑Cola cannot, however, fully eliminate security risks associated with the processing of personal information.  

You are responsible for maintaining the security of your account credentials. Coca‑Cola will treat access to the Services through your account credentials as authorized by you. 

Coca‑Cola may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security.  If you believe that information you provided to Coca‑Cola or your account is no longer secure, please notify us immediately at Privacy@coca-cola.com.

If we become aware of a breach that affects the security of your personal information, we will provide you with notice as required by applicable law. When permitted by applicable law, Coca‑Cola will provide this notice to you using the email address associated with your account or another permitted method associated with your account.

UNAUTHORIZED ACCESS TO PERSONAL INFORMATION THROUGH THE SERVICES – INCLUDING SCRAPING – IS PROHIBITED AND MAY LEAD TO CRIMINAL PROSECUTION.

We intend to keep your personal information accurate and up-to-date.  We retain the personal information that we handle subject to this Privacy Policy in accordance with our data retention policy.   When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you and mandatory retention periods under applicable law.  At the end of relevant retention period, we either delete or anonymize personal information or, if we cannot delete or anonymize personal information, then we segregate and securely store personal information until deletion or anonymization is possible.  

Once we anonymize personal information, it is no longer personal information. We use anonymized data subject to applicable law and contracts.

When we update this Privacy Policy, we will post the updated version and change the Effective Date above.  We also will take appropriate measures to inform you in advance of significant changes that we believe affect your privacy rights so that you have an opportunity to review the revised Privacy Policy before it is effective.  If your consent is required by applicable privacy laws, we will obtain your consent to changes before the revised Privacy Policy applies to you.  Please regularly check this Privacy Policy to ensure you are aware of the updated version.