PRIVACY POLICY

This Privacy Policy describes the use, handling and transfer of personal data gathered from the www.ajegroup.com URL (hereinafter, the Website), which will be processed, handled and managed according to the legal provisions of the country in which the File Manager is located, which is Spain in this instance. The corporate name of the owner and guarantor of compliance with the principles and rights governing the matter of privacy is Grupo Embotellador ATIC S.A. with its main offices at Avenida de la Vega, 1 Edif.2, 5ª Pl. 28108 Madrid, Spain (hereinafter, “AJE”).

AJE, in its capacity as a multinational beverage company with an extensive and long-standing international history, is highly aware of the legal need for protection of an environment as sensitive as that of the fundamental right to privacy, and declares its firm commitment to ensure compliance with the principles and rights arising from current rules on data protection so as to protect the security and confidentiality of personal data that may be handled as a result of the use made of the website by its visitors.

This policy details the data compilation and dissemination practices of the company and its brands (BIG, BIG Fresh, Pulp, Cifrut, Cielo, Cool Tea, Sporade, Volt).

AJE advises that merely by accessing and using the services and content included in the website, users agree to the collecting of personal data as a consequence of their browsing of the website.

It is also advised that this website does not in principle gather personal data by means of any type of form or questionnaire, merely providing one or several email addresses so that users can send the information they may consider necessary. Communication of personal data by users by means of this system implies express acceptance and consent by the user for the handling of the data for the specific purposes arising from such communication.

The data contributed by users, including personal information obtained and used by the company or its brands will be subject to handling on a file or database of personal data that has been duly notified to the corresponding authority in the country in which it is located.

 

I) Information gathered and its purpose.

Although in principle AJE does not actively gather personal data via the website, it may occasionally obtain personal data without infringing the principles and guarantees established in the law, such as names, addresses, telephone numbers, and emails, necessary to participate in sweepstakes, contests, subscriptions to newsletters, participation in surveys and/or any other activity or form of data collection. Use, handling and communication will be in accordance with the terms of this Privacy Policy, while the purpose will be to attend to, manage and/or respond to the participation or request being submitted.

Occasionally, AJE may obtain “demographic information” that consists of the compiling of statistical demographic information, such as your date of birth, sex or country. Information of a demographic nature may be used to optimise user website experience, for example by showing specific special event and advertising content that may be of interest to you, as well as to show content appropriate to the country or region from which the connection has been made.

Nevertheless, AJE may in a passive manner compile user browsing data (understood as that whereby users do not actively provide information; and specifically, information will be obtained in relation to the browsers and operating systems being used, the webpage from which visited, the pages viewed and the date of visit, among others) using different technologies, mediums and processes such as IP addresses, cookies, internet labels and browsing data collection, among others. In the case of cookies, see the terms of the Policy on Cookies prepared for the purpose; please also review the cookie configuration panel for specific details on cookies and other tracking technologies used by the website.

Human Talent Department (careers@ajegroup.com) will be responsible for compliance with the rights included in Data Protection regulations regarding the receipt of emails from users in relation to the “Candidates” section, as they will receive the information and will comply with all existing legal requirements.

 

II)  Who we share your information with

To comply with the indicated purposes, it may be necessary for us to communicate the information provided to us to certain companies belonging to the AJE group, so that when browsing, registering and/or providing us with information through this website or by other means, such as email, you expressly authorise us to carry out such communication based on shared sales promotions, competitions, surveys, information updates and/or requests for information, all of which will take place as indicated below.

In view of the foregoing, therefore, the communication or disclosure of information gathered via the website may be made to:

  • Group companies

For the purpose of attending to and handling requests that may be made, as well as for the processing of browsing for the indicated purposes, information may be shared through the website with our subsidiaries and affiliates anywhere in the world.

  • Brands and business partners

To add functions to the Website or implement the benefits offered to our customers, business links may be entered into with companies that do not belong to AJE. These special links will be entered into with commercial partners, sponsors and branded company pages (brands). Any information, including identifiable information that you provide on one of these co-branded pages will be shared with these third party partners. By participating in activities or providing information on these co-branded pages, you also consent to our sharing your personally identifiable information with these third party partners. As these third parties will make use of the information in accordance with their own privacy policies, we recommend that you review the information on the various privacy policies of the different websites.  

  • Service providers

In some cases it is necessary to contract external service providers for help in the daily operations of the business and Website management, as well as to manage activities in our name, such as hosting, data analysis, processing, infrastructure, IT services, customer attention and help desk, email services, and the administration of sweepstakes, surveys and competitions that may be advertised, either our own or those of third parties. In these instances, the service provider will assume its condition as a service provider, with a formal legal commitment to process data for the purposes ordered and specifically authorised by AJE, and must destroy and return them at the conclusion of the service.

 

III)Links to third parties

Our Website and our services may contain links to other services and websites not operated or controlled by us that might compile Personal Information and General Information provided directly by you. In addition we may use third parties to provide components for our systems. In any of these cases, third parties may have different privacy policies, as well as independent information-gathering practices. The links that appear on our website do not imply that we have certified or reviewed those third party services. We suggest you contact those sites directly to obtain information on their privacy policies. We (a) have no responsibility for or obligation in relation to these policies or actions of third parties and (b) we are not responsible for the privacy policies or content of those websites.

 

IV) Social Plugins

Various website pages show Social Plugins for social networks such as Facebook and Twitter for example. These plugins are inactive by default, so that users will not send data to social networks as long as they are not activated.

Once activated, the social plugin will establish a direct link to the server of the corresponding social network, and the social network will be responsible for the use and processing that may be given to the browsing cookies. However, if you are a member of a social network and you do not wish to establish links between the data collected during your browsing of our website and the user account of the social network concerned, you must shut down your network session, thus preventing such information from being gathered by the social network. To this end, we would advise that AJE waives all responsibility derived from the data collected by the social network of which the user is a member, as it is outside its control

 

V)  Information security

This Website is equipped with the technical and organisational measures necessary to ensure the security and confidentiality of the personal data collected through the Website and avoid its alteration, loss, unauthorised access or treatment. Likewise, AJE adopts security measures based on standard sector practices to help to protect against unauthorised public access of the personal information that the entity itself collects and uses on this Website.

AJE cannot guarantee that the Internet network is totally impregnable and that data cannot therefore be breached by means of fraudulent access by third parties, but it will fulfil its duty of care to maintain and ensure compliance with measures designed to prevent such unauthorised access. It will however use all means and resources at its disposal to prevent breaches of security and unauthorised access. If you consider that your privacy may have been compromised by any act or omission by AJE, please let us know as soon as possible so that we can immediately resolve the matter and repair the information breach that has taken place.

Furthermore, it recognises and guarantees its observance of all regulations on Data Protection and undertakes to comply with its secrecy obligations in relation to personal data, as well as to keep and protect them in accordance with the measures indicated.

 

VI) ARCO Rights

The data obtained by AJE and its brand will be handled correctly so as to respond to the requests you may make, send you the information requested, and administer your access to certain services or functionalities of the website when necessary. Information on its owners shall not be notified to third parties in any event, except as indicated under “Information sharing.”

AJE and its brands undertake to observe the confidentiality of information of a personal nature and to guarantee the exercise of the rights of access, rectification, cancellation and objection. To exercise these rights you must address an email to dataprotection@AJE.com.

If necessary, to answer your request we may require you to present a copy of your identity document, passport or other valid document identifying you, given the very personal right that is being exercised.

 

VII) Changes to this privacy policy

AJE reserves the right to make such changes as it considers advisable to this privacy policy. If a significant change is made to this policy, it will be made public in this document. We recommend that you visit this page regularly, as the use of this Website after any change that has been made to this Privacy Policy constitutes acceptance of such changes.

 

VIII) Contact information

To keep your personal information updated and complete, and in order to comply with the principle of the quality of the data collected required under current legislation, we would ask you to let us know of any changes to such information. In a similar manner, in addition to keeping their data updated, users shall warrant the truthfulness, exactness and validity of the information they have provided, undertaking to keep it permanently updated.

Likewise, do not hesitate to contact us if you have any question on this Privacy Policy via our email address: dataprotection@AJE.com