PRIVACY, SECURITY AND PROTECTION OF PERSONAL DATA POLICY (“this Privacy Policy”)

(effective as of 19th February 2024)

Save as otherwise defined herein, the definitions in the Coke Buddy Terms and Conditions (the “Terms and Conditions”), shall apply to this Privacy Policy. By clicking on the "accept" button and / or using the Platform, the User expressly consent to CCSB’s collection, storage, use and disclosure of the User’s personal data as described in this Privacy Policy. Should the User revoke its agreement to this Privacy Policy, the User’s access to the Platform may be suspended or terminated. CCSB values your privacy and is committed to protecting your Personal Data (as defined hereinbelow) entrusted to us.

CCSB will only collect, record, hold, use, disclose and store (i.e., "process") your personal information in accordance with such laws (including the Personal Data Protection Act 2012 (“the Act”) and other applicable data protection or privacy laws / regulations), this Privacy Notice and the Terms and Conditions.

A. Types of Personal Data Collected
1. The Platform collects personally identifiable information when the User registers with it and makes use of it.

2. The Platform also automatically receives and records the information from the User’s browser, including the User’s IP address, in CCSB’s server’s records. If you do not agree with this Privacy Policy or is not agreeable to provide CCSB with the required data, please do not register with or use the Platform.

3. Where the User shares and / or transfers Personal Data of third parties to CCSB, the User represents that it has obtained the express consent of the respective holder of the data for such disclosure, as required under the Act. TCCC and/or CCSB may disclose your Personal Data or the aforementioned Personal Data of third parties as provided by the User, to its affiliates, vendors and professional advisors in order to operate the Platform.

4. The personal data (name of person-in-charge, contact number, delivery address, email address, and other information whereby User is rendered identified or identifiable, collectively “Personal Data”) provided by the User or that are collected through the Platform will be collected and transmitted into a data bank operated by CCSB and to which TCCC has access as platform owner. The User gives its express consent for the collection and processing of its information (including any Personal Data) in the aforementioned data banks and the use of it for the purposes and scope mentioned below.

B. Use of the Personal Data Collected
1. The Personal Data and other information provided or collected through the Platform will be used for the purpose stated in this Privacy Notice as well as in the Terms and Conditions.

2. In particular the Personal Data provided or collected through the Platform will be used for the purpose of perfecting contracts, carrying out transactions on the Platform, validating orders, receiving payments, assessing your feedbacks and complaints, to manage and maintain your account(s) with us, to better manage our business and your relationship with us, to understand your behaviour so that we can improve our current and future products, services and advertising needs, to administer offers and promotions, receiving information about promotions and other products, to update, consolidate and improve the accuracy of our records, improving the commercialization of the products offered, generating information, data, reports and statistics which have been anonymised or aggregated to ensure that you are not identifiable as an individual and conducting research for purposes of analysis including but not limited to the processing or information as well as the management and enhancement of data, data mining and analysis of your transactions with CCSB.

3. In their use of the Personal Data, CCSB will comply with this Privacy Policy and the legal provisions in force regarding personal data protection, in particular with the Act, and will act in good faith at all times.

C. Disclosure of the Personal Data
1. The User expressly accepts that Personal Data will be shared or transferred to the manufacturers and/or owner and/or licensees of the trademarks of the products for the purposes of their processing, including, without limitation, the history of orders and purchases. The inaccuracy or falsity of the data provided by the User, or the absence of any of them, will invalidate its right to claim for any error or damage related to the delivery.

2. The User knows and accepts that Personal Data can be transferred and assigned, locally and cross-border, to companies or persons indicated in the Terms and Conditions (including to any future application, website or database that CCSB decides to use for the online sale or distribution of the product offerings), ensuring the proper handling and reservation of said information. Likewise, it accepts the cross-border flow of said information to companies handling the storage and / or processing of databases.

3. Personal Data will be processed and stored on servers or magnetic media that maintain appropriate standards of security and protection, both physical and technological, and is managed in accordance with the provisions of the Act.

4. CCSB may, upon receipt of a requirement from any legal, governmental or regulatory enforcement bodies, disclose your Personal Data in the event of an investigation of any potential or ongoing criminal or civil wrongdoing.

D. Access To and Correction Of Your Personal Data
1. The User has the right to exercise the rights of access, rectification, cancellation or deletion of its Personal Data by sending an email to the email address stated in this Privacy Policy, and attaching the following scanned documents, where applicable:

(a)        Simple and readable copy of proof of amendment (if we deem it necessary); and/or
(b)        In case of representation, a simple and legible copy of the validity of the proxy or power of attorney legalized by a notary public that empowers him/her to act on the holder’s behalf

Depending on the request, the User must attach the documents that support its request.

2. The User can request to access, review, update and correct and limit /revoke the processing of its Personal Data which we have collected by contacting us at sophy.wong@coca- cola.com.sg. CCSB will respond within 21 days from the date of the request and CCSB reserves the right to charge a reasonable administrative fee for retrieving the User’s Personal Data, the amount of which will be communicated to the User. If we are unable to respond within 21 days from the date of the User’s request, we will notify the User in writing to inform the User that we are unable to comply with the User’s request and the reasons for not being able to do so.

3. Please ensure the Personal Data provided to us (such as your mailing address(es), e-mail address(es) and telephone number(s)) are current, complete and accurate. Please notify us of any change in your Personal Data via the channels made available by us to ensure that all correspondence and/or communication reach you in a timely manner and to enable us to serve you better.

E. Period of Retention of Your Personal Data
1. The User’s Personal Data shall be retained by CCSB for as long as it is required by law or to fulfil the above purposes that the Personal Data was collected for. We will cease to retain and remove all your Personal Data once it is ascertained that the retention of Personal Data is no longer necessary.

F. User’s Responsibility
1. User is responsible for ensuring that the Personal Data provided to CCSB is accurate and complete. The User is also responsible for updating the Personal Data in the event of any changes or as and when it becomes inaccurate, outdated or incomplete. We will not be responsible for the veracity, accuracy, validity and authenticity of the Personal Data entered by the User on the Platform.

2. The User is responsible for maintaining the confidentiality of its account, username and password, and assumes responsibility for all activities performed on its account.

G. Security of Your Personal Data
1. CCSB will use its best endeavours to keep and process your Personal Data in a secure manner. We will implement the appropriate and necessary security safeguards and procedures to prevent the unauthorized and accidental access, use, modification, processing, loss, destruction of or damage to your Personal Data.

H. Links to Third Party Websites
1. This Privacy Notice does not apply to third party websites or applications that the User may access from the Platform. These third part websites or applications may have their own privacy policy in place.

I. Changes and Updates to this Privacy Notice
1. This Privacy Notice may be amended from time to time. You are advised to regularly check the Platform for any changes and/or updates to this Privacy Notice. By continuing to use the Platform, the User expressly consent to CCSB’s collection, storage, use and disclosure of the User’s personal data as described in the updated/amended Privacy Policy.