SPVB PRIVACY POLICY

(for Business Partners, Consumers, Third Parties, Candidate and other related Data Subjects) 

Last updated: 01 July 2023 

It is our aim through this Privacy Policy (“Policy”) to explain what personal and other information that we, Suntory PepsiCo Vietnam Beverage Co., Ltd. ("SPVB"), collect about you and why we collect that information. We also want to make sure you understand how we use and share your information and the choices available to you. We treat your data with respect and in compliance with the laws. We do not buy or sell your personal data. Our goal is to earn and keep your trust as you visit websites and applications about our products and brands.

This Policy describes how we treat personal information on websites (“sites”), mobile or social media applications (“apps”), and any other services or circumstances where we include an authorized link or reference to this Policy (together, the “Services”). This Policy does not describe our practices on sites or apps where it is not referenced. Your use of our apps and sites indicates you agree to our collection, use, and sharing of your information as set forth in this Policy.

If you do not want your personal data to be collected, used or disclosed in the manner set out in this Policy, please do not provide us with your personal data. However, in such a case, you understand that some of the functionality and/or availability of the Services may no longer be available to you.

WHAT INFORMATION DO WE COLLECT?

We collect your profile identifiers and contact information. For example, we may collect your name and street address if you register on our site or apps. We may also collect your phone number or email address. We also collect identifiers. For example, if you engage with us through a social media site, we may collect your social media user identifier. We may also collect photograph or video of you. For example, if our Services need your image to verify your identity.

We collect information you submit or otherwise provide or authorize us to collect. We collect the information you post in a public space on our site. This includes comments and videos or photos. We also collect any other information you may provide to us or authorize us to collect. This may include information about your physical activities or your nutrition preferences.

We collect demographic information and information about your interests. We may collect information such as your gender and age, household or lifestyle information, and your zip code.

We collect internet and electronic network activity information, such as device and usage information. We may collect information about the browser you are using, and we may look at what site you came from, or what site you visit when you leave us. We may also collect information about your operating system, Internet Service Provider (ISP) information and IP addresses and other device identifiers, such as mobile device identifiers. In addition, we may collect information about your use of our Services, including through use of tracking technologies such as cookies, pixel tags, and similar technologies.

We collect job application information, such as professional or employment-related information and education information. We collect information if you apply for a job with us. This information may include your education and work history, your skills, and qualifications for the position. We may ask about how you learned about the position. If applicable, we may ask about your driving record and your ability to perform the position. We may also collect the last four digits of your social security number and your nationality.

We collect your image and registration information. For example, we may collect your images when you visit our offices, our business locations. We may also collect your phone number or email address.

We collect information about third parties. From time to time, we may allow you to send an email or message to a friend through one of our sites or apps. If you choose to do this, we will need that person’s name and email address.

WHAT SENSITIVE PERSONAL INFORMATION DO WE COLLECT?

We collect payment information. If you make purchases with us, we (or our business partners who process payment cards for us) may collect your billing information. This includes your payment card number.

We collect geolocation information. Using technologies such as GPS or Wi-Fi, we may collect information about your location. For example, if you use our mobile apps, we may access your device’s location information to provide you location-enabled features.

HOW DO WE COLLECT INFORMATION?

We collect information directly from you. We collect information from you when you:

·         Make a purchase with us.

·         Register on one of our sites or apps.

·         Join our loyalty programs.

·         Apply for a job.

·         Sign up for our email newsletters and other notifications.

·         Participate in promotions such as gifting or contests.

·         Visit our premises or events.

·         Fill out a survey. 

·         Contact us.

·         Otherwise submit it to us.

We collect information from you passively. We use tracking tools like browser cookies and mobile device IDs. We do this on our websites, in emails that we send to you, and in media advertising. We collect information about usage and browser information over time. We may have third parties collect personal information this way. We also collect information about you from our mobile apps.

Third parties may also share information about you with us. For example, our business partners may give us information about you. We may receive information from companies who compile information about shoppers and their preferences. Social media platforms may also give us information about you, and we may get information about your interactions with our ads on third-party sites.

We may combine information. For example, we may combine information we have collected offline with information we collect online. We combine information we have collected across third-party sites, including social media sites. We combine information across devices such as computers and mobile devices. We may also combine information from third parties with information we already have.

HOW WE MAY USE THE INFORMATION WE COLLECT

We may use information to help us effectively provide you products and services. We use your information to respond to your questions or enable you to participate in our programs. This may include sweepstakes or contests. Another example is that we may use your information to process your registration with sites and apps. We may use your friends’ email addresses to send them information you requested we send them. We also use your information to process orders for you. We may also contact you if you have won a prize or promotion.

We may use information to improve our products and services. One of our goals is that you have a positive experience with our sites, apps, and products. Therefore, we may use your information to improve your experience with our sites, apps, and products. We might use your information to personalize your experience with us. We may use information you provide or that third-party partners give us to personalize your experience.

We may use information for security purposes. We may use your information to help protect you, our sites and apps, our company, our customers, and our consumers.

We may use information for marketing purposes. For example, we might send you information about products, offers, features, or updates. We might also use your information to serve you ads about products and offers. Those ads may appear on third-party platforms which may include social media. These might be our own offers or products, or third-party offers or products we think you might find interesting. We may provide you with information through email or push notification.

We may use information to get feedback from you about how we’re doing and for other transactional purposes. We may contact you about this Policy or the Terms of Use posted to the sites or apps you are using. We may also communicate with you about a job application or your questions about our products or promotions.

We may use information as the law allows us or as you have consented us.

HOW WE MAY SHARE INFORMATION WE HAVE COLLECTED

We may share information within the SPVB family of companies and brands. This includes current and future SPVB subsidiaries, affiliates, and joint venture partners, inside or outside of Vietnam. We may also share information with third parties with which we have an ownership interest or commercial relationship, such as companies whose products we distribute.

We may share information with third-party vendors. We may share information with companies who serve as our vendors or third parties who perform services on our behalf, inside or outside of Vietnam. They may help us deliver products or services to you. For example, we may share information with companies who operate our sites and apps or who run our promotions.

We may share information with select business partners. For example, we may share information with joint promotion partners, inside or outside of Vietnam. If you register for a joint promotion, your information may be collected by both us and the third party. This might include retailers. Your information will be used by us as described in this Policy or by promotion partners as described in their policies.  

We work with analytics and advertising partners. Our online Services may use analytics, advertising and other third-party content or functionality through which our partners may collect internet and electronic network activity information, such as device and usage information.

We will share information if we think we must in order to comply with the law or to protect our company. For example, we will share information to respond to a court order or competent authority's request. We may share information if a government agency or investigatory body requests it. This includes Vietnam and non-Vietnam law enforcement or regulatory authorities. We may also share information if we are investigating potential fraud.

We may share information with any successor to all or part of our business. For example, if part of our business is sold we may include your information as part of that transaction.

If there are additional reasons we may share information, we will describe those to you in an appropriate manner.

YOUR RIGHTS, OBLIGATIONS AND CHOICES

Your legal rights. You have certain legal rights under applicable law about how we use your information, such as the following:

·         Right to know;

·         Right to consent;

·         Right to access;

·         Right to withdraw consent;

·         Right to delete data;

·         Right to restrict data processing;

·         Right to be provided with data;

·         Right to object data processing;

·         Right to complain, to denounce, to initiate lawsuit;

·         Right to claim for damages; and

·         Right to self-protection.

These rights are subject to entitlements and exceptions under applicable laws. For example, we may not be able to honor certain rights requests without taking steps to verify your identity.

If you would like to exercise these rights under applicable privacy laws, you or your authorized agent have two options for doing so:

·         Email us: You may email us at our address, compliance.privacy@suntorypepsico.vn; or

·         Submit Online: You may submit your request through our secure web portal, https://www.suntorypepsico.vn

We may verify your request by asking you to provide information to confirm your identity. This information may vary depending on your relationship with us.

Your legal obligations. You have certain legal obligations under applicable law about your information, such as the following:

·         Provide complete and accurate personal data upon giving consent to the processing of your personal data.

·         Protect your own personal data and request other to do the same.

·         Respect and protect the personal data of others.

·         Other obligations under applicable laws.

You can opt out of email marketing. To stop receiving promotional emails from us, follow the instructions in any promotional email message you get from us. If you opt out of getting marketing email messages, you may continue to receive non-marketing email messages from us where permitted by law.

You can control cookies and tracking tools. Some web browsers transmit "do-not-track" signals to websites. Because the standards for these signals are still under development, we currently do not take action in response to these signals.

You can control tools on your mobile devices. For example, you can turn off the GPS locator or push notifications on your phone. To modify the push notifications you get from our app, you can alter your preferences in your profile.

Your choices. If you choose certain choices and/or options, you understand that some of the functionality of the sites, apps and/or services may no longer be available to you.

RETENTION OF PERSONAL INFORMATION 

We keep the categories of personal information described above for as long as is necessary for the purposes described in this Policy or otherwise authorized by law. This generally means holding the information for as long as one of the following apply:

·         Your personal information is reasonably necessary to manage our operations, security and properties, to manage your relationship with us, or to satisfy another purpose for which we collected the information;

·         Your personal information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the personal information was collected;

·         The information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or

·         We are otherwise required or permitted to keep your information by applicable laws or regulations.

CHILDREN'S PRIVACY

It is not our intention to collect personal information from children without necessary parental consents. If you are a parent or legal guardian and think that your child has given us information, you can contact us at compliance.privacy@suntorypepsico.vn and we will take appropriate steps.

SECURITY MEASURES

We use various technical and organizational mechanisms to secure our websites and apps. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be perfectly secure.

WE MAY LINK TO OTHER SITES OR APPS OR HAVE THIRD-PARTY SERVICES AND TOOLS ON OUR PLATFORM WE DON'T CONTROL

We may link to or allow you to access the Services from third-party websites or platforms. Our sites and apps may also include third-party content that collects information. Third-party content may include tools like cookies and tracking technologies. These third parties may use your information for their own purposes. This may include behavioral advertising and analytic purposes. We do not control these third parties or their use of these technologies, so please read their privacy policies carefully.

WE MAY UPDATE THIS POLICY

From time to time, we may change this Policy. When we do, we will notify you of any material changes as required by law. This may include posting an updated copy here and updating the “Last Updated” date. Please check this Policy periodically for updates. By continuing using the sites, apps and services, you voluntarily and expressively agree with the updated Policy.

OUR SERVICES ARE INTENDED FOR A VIETNAM AUDIENCE

If you are outside of Vietnam, please visit the site designated for you. If you live outside of Vietnam and choose to use this site or app, you understand that it is at your own risk. This Policy is governed by Vietnamese law, and any disputes arising from this Policy shall be handled by competent courts in Vietnam.

FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS

If you have questions about this Policy or our data practices, please click  [HERE] to submit your question. You can also write to us or call us at:

Suntory PepsiCo Vietnam Beverage Co., Ltd.

Attn: Compliance Department

88 Dong Khoi, District 1, Ho Chi Minh City, Vietnam.

Tel: (84 28) 3 821 9437