Last Updated: 28 April 2023
This Policy describes how we treat personal information on websites (“sites”), mobile or social media applications (“apps”), and any other services 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.
As you read this Policy please keep in mind that it applies to Tropicana Products Ltd. and its subsidiary companies, together with Duo Juice Company B.V. Tropicana Products UK Ltd. is the controller of the personal data we collect on the site. Tropicana Products UK Ltd. or the local Tropicana Brands Group entity will be the controller of the personal data which we collect on the local brand-specific site.
Please keep in mind that our websites and applications may contain hyperlinks to third party sites or platforms. The personal information the third-party site or platform collects is subject to the third-party site or platforms privacy practices. We encourage you to be aware when you leave our websites or applications and to read the privacy notices of other sites that may collect your personal information.
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.
WHAT INFORMATION DO WE COLLECT?
Personal data means any information that relates to an identified or identifiable individual. This definition includes personal data collected either offline or online through our consumer engagement centres, direct marketing campaigns, competitions, websites, applications and branded pages on third-party platforms, applications accessed or used through third-party platforms and our recruitment / job application channels.
We may collect personal data from a variety of sources. This includes:
- Personal data you provide to us directly,
- Personal data we collect automatically, and
- Personal data we collect from other sources.
We collect 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 online identiﬁers. For example, if you engage with us through a social media site, we may collect your social media user identiﬁer.
We collect payment information. If you make purchases with us, we (or our business partners who process credit cards for us) may collect your billing information. This includes your credit card number.
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, for example when you sign up for a marketing newsletter, complete a survey enter a competition or otherwise communicate with us through our online channels. 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 postcode/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 Flash Cookies. For additional information, please visit our About Our Ads policy here.
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.
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 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.
Special categories of personal data. Certain categories of personal data, such as race, ethnicity, religion, health, sexuality or biometric data are classified as “special categories of data” and benefit from additional protection under UK and European Union data protection legislation.
We limit the circumstances where we collect and process these special categories of data. However, we may collect such data in the following circumstances:
- if you contact us to discuss an experience with a product, you may provide certain health information relating to your dietary requirements;
- if you apply for a job at Upfield, we may collect information about you relating to pre-existing health conditions (for example if you have a disability that we need to be aware of), or information about your religion.
TBG only collects and uses this personal data where you have provided us with your explicit consent for us to do so or where we are legally required to process such data. In some instances, you may provide us with information which does not directly involve the collection of any special categories of data, but may imply or suggest your religion, health or other special categories of data.
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 programmes;
- apply for a job;
- sign up for our email newsletters and other notiﬁcations;
- participate in promotions such as sweepstakes or contests;
- ﬁll out a survey; or
Otherwise contact us or 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, when your web browser accesses other content served by or on behalf of Tropicana Brands Group on other sites, 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 COMBINE INFORMATION FROM DIFFERENT SOURCES
We 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 USE THE INFORMATION WE COLLECT
We 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 programmes. This may include sweepstakes, prize draws or competitions. We may also 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 and to authenticate the identity of individuals contacting us by telephone, electronic means or otherwise. We may also contact you if you have won a prize or promotion.
We 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 and provide product recommendations. We may use information you provide or that third-party partners give us to personalize your experience.
We 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 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 also create profiles by analysing the information about your online surfing, searching and buying behaviour and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your personal data in one or more segments.
We use information as the law allows us or as we may notify you.
WE SHARE INFORMATION WITH THE TROPICANA BRANDS GROUP BRANDS AND AFFILIATED THIRD PARTIES
We share information within the Tropicana Brands Group family of brands in the UK, Switzerland and Europe. This includes current and future Tropicana Brands Group subsidiaries, afﬁliates, and joint venture partners. This also includes current brands such as Tropicana, Naked, Copella, and all future brands. You can find a list of Tropicana Brands Group brands in Europe here. 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 share information with our business partners and third-party vendors. For example, we may share information with joint promotion partners. 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 may also share information with companies who serve as our vendors or third parties who perform services on our behalf.
They may help us deliver products or services to you. We may share information with companies who operate our sites and apps or who run our promotions.
We will share information if we think we must to comply with the law or to protect our company. For example, we will share information to respond to a court order or subpoena. We may share information if a government agency or investigatory body requests it. This includes 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.
INTERNATIONAL DATA TRANSFERS
Your personal data will be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
However, we have taken appropriate safeguards to require that your personal data will remain protected in accordance with this Policy. For example, our safeguards include implementing the European Commission’s Standard Contractual Clauses for transfers of personal data to non EEA-based third parties and between our group companies, which require all companies to protect personal data they process from the EEA in accordance with European Union data protection law. Further information regarding these safeguards is available upon request.
LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
We generally rely on legitimate interests for processing your personal data (as long as our legitimate interests are not overridden by your data protection interests or fundamental rights and freedoms). Our legitimate interests could exist for example, when you sign up to receive information about one of our brands or enter a competition and we use the personal data collected to better understand the needs of our customers.
In some cases, we process your personal data to perform a contract to which you are or will be a party. For example, we need to process your personal data to allow you to take part in one of our competitions, or to send you samples that you have requested.
We also process your personal data when we have a legal obligation (e.g., tax or social security obligations) to perform such processing. For example, a court order or a subpoena may require us to process personal data for a particular purpose.
Where appropriate (such as if we are collecting special category personal data for allergen related purposes, voluntary surveys regarding our products or staff diversity reasons), we will ask for your consent to process the personal data. Where you have given consent for processing activities, you have the right to withdraw your consent at any time. For further information on how to do this, please see the Contact Us section below.
Like most organisations with an online presence, Tropicana Brands Group uses your personal data to build profiles. We create profiles by analysing information about your online surfing, searching and buying behaviour and your interactions with our brand communications by building segments (creating groups that have certain common characteristics) and by placing your personal data in one or more segments. These segments are used by Tropicana Brands Group to personalise the website and our communications to you (such as showing relevant content to you when you visit our site or in a newsletter to you), and to display relevant offers and advertisements from the Tropicana Brands Group brands on our sites, and via third-party websites. The segments can also be used for third-party campaigns on our sites. Tropicana Brands Group profiles your data using cookies where you have provided consent for us to do so; for example, accepting the setting of cookies on your browser online. For more information, see our Cookie Consent Manager.
If you have asked to receive emails or SMS communications from us, we track whether you open, read or click on the content to see what you are interested in so that we can give you more content that we think you are more likely to enjoy.
We use this data to profile your likes and dislikes. Based on this profile information, we may also give you advertising that we think you will like and want to see as you view content from us or from our network of publishers that we advertise with. Sometimes we may use your current location to serve advertising to you that is to do with promotions or events that are happening nearby that we think you might be interested in.
We may also use information you have provided to selected third-parties and consented to be shared, like your age, gender, life stage, lifestyle and wider interests to identify people who we think will have similar interests to you and who we believe will be interested in similar advertising.
In some instances, Tropicana Brands Group processes your personal data using automated means. An automated decision is a decision which is made solely by automatic means, where no humans are involved in the decision-making process related to your personal data.
We will not make decisions based solely on automated decision making that have significant impact on you. If we do so we notify you and provide you with clear information about our decision to rely on automated processing to make our decision and our lawful basis for doing so. For example, Tropicana Brands Group processes your personal data using automated means only if it is necessary for the entering into or the performance of a contract with you, or when you have given your explicit consent.
You have the right not to be subject to a decision which is based solely on automated processing and which produces legal or other significant effects on you. In particular, you have the right:
- to obtain human intervention;
- to express your point of view;
- to obtain an explanation of the decision reached after an assessment; and
- to challenge such a decision.
YOU HAVE CERTAIN CHOICES ABOUT HOW WE USE YOUR INFORMATION
You have the following data protection rights:
- You have the right to access, correct, update or request deletion of your personal data at any time. We understand the importance of this and should you want to exercise your rights, please contact us.
- The right to data portability. The personal data you have provided us with is portable. This means it can be moved, copied or transmitted electronically under certain circumstances.
- Under certain circumstances, you have the right to restrict or object to certain types of processing, including processing for direct marketing (i.e., receiving marketing emails from us or being contacted about potential opportunities, events and promotions).
- You have the right to lodge a complaint directly with any local Supervisory Authority about how we process your personal data.
- If you have given your consent to anything we do with your personal data (i.e., we rely on consent as a legal basis for processing your special category personal data), you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). You can withdraw your consent to the processing of your personal data at any time by contacting us with the details provided below.
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.
Do-Not-Track Signals and Similar Mechanisms. Some web browsers transmit “do-not-track” signals to websites. Because the standards for these signals are still under development, we currently do not act 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.
It is not our intention to collect personal information from children under age 13. If you are a parent or legal guardian and think that your child under 13 has given us information, you can contact us at firstname.lastname@example.org and we will take appropriate steps. You can also write to us at the address listed below. Please mark your inquiries “GDPR Article 8 - Children's Privacy.” Parents, you can learn more about how to protect children’s privacy online here and the specific Article 8 here.
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.
FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We retain your personal data we collect from you where we have an ongoing legitimate business need to do so, and we only retain your personal data for no longer than is necessary to fulfil the purpose for which it was originally collected. For example, where you make a submit a query to us online, we will keep the personal data for a period which enables us to handle or respond to any complaints or concerns regarding our response or your query.
Your data may also be retained so that we can continue to improve your experience with us and to ensure that you receive any loyalty rewards which are due to you.
We retain the personal data we collect directly for targeting purposes for as little time as possible, after which we employ measures to permanently delete it.
We will actively review the personal data we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or consumer need for it to be retained. If this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
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.
FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS
If you have questions about this Policy or our data practices, or if you would like to submit a request, please contact us at email@example.com. You can also write to us at:
Tropicana Products UK Ltd.
Attn: Consumer Relations
10 Fetter Lane,
London EC4A 1BR.
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 will include posting an updated copy here and updating the “Last Updated” date. Please check periodically for updates.