Privacy last updated: April 4, 20211. Our Commitment To Privacy
1. Your privacy is very important to us at SodaStream Australia Pty Ltd (ACN 104 202 093) and its affiliates, hereinafter also "we" and/or "us" and/or "SodaStream").
4. We strongly urge you read this policy and make sure you fully understand our practices in relation to personal data, before you access or use any of our services. You may wish to interact with us by not identifying yourself or using a pseudonym, and where possible we will allow this.
2. Important information
2. Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information on our website or offline from those we actually know are under 18, and no part of our website is structured to attract anyone under 18. Parents and guardians should supervise their children's activities at all times. If we learn we have collected or received personal data from a person under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us at email@example.com.
3. What information do we collect and how do we collect it?
2. If you register on our website, contact us as an individual or purchase any products or services from our website, we may collect your name, email address, telephone number, address information (together, "identification data"); information about your household ("household composition data"), the consumption habits of you and members of your household ("consumption data"), information about the device you use to access our website or online services ("device data"), payment and credit card information ("payment data"), information to set up and access your SodaStream account ("login data").
3. If you register or contact us on behalf of a company, we will collect company identification data, identification data from the company representative, company composition and consumption data, device data, payment data and login data.
4. If you contact us by other offline methods in order to buy our products or services or by using one or more of the contact means provided offline, we will collect identification and payment data as relevant for the sale and delivery of the goods and services or to respond to your query or complaint and, as far as necessary, for the handling and fulfilment of the order and ongoing provision of our services.
6. If you apply to one of our open positions published in our careers sites, by sending us contact details and CV ("applicant personal data") via the relevant application on our website, or through any other means provided by us (e.g . social media), we will collect such applicant personal data in order to process your application.
4. How do we use your personal data?
1. To provide our products and services
- We collect personal information in order to offer our products and/or services and their functions. We may use the information collected in order to validate your order or subscription, to process your payment (for instance, a monthly fee in the case of a subscription) and to provide the products and services that you requested, ordered or to which you subscribed. We will also use your personal information as far as necessary for the handling and fulfilment of your order as well as to provide customer support.
- We also use this information for customer management purposes, to maintain our relationship with you, with a view to providing stellar customer experience.
- We may use the information collected from you to verify your identity. We may also use this information to establish and set up your account, verify or re-issue a password, log your activity and contact you from time to time.
- to improve our products in order to make them fit for our customers' needs and to draw insights in relation to possible improvements;
- to improve our services to you and customize your browsing experience. Some of the information (particularly the information collected by cookies and other tracking technology) helps us improve our website; and
- to track any fraudulent activities and other inappropriate activities and monitor content integrity on our website.
We collect applicant personal data solely for SodaStream's internal recruitment purposes including for the purpose of: identifying applicants, evaluating their applications, making hiring and employment decisions, and contacting applicants by phone or in writing.5. To communicate with you
We use your personal information to respond to your queries and/or complaints about our products or services, and to provide you important information about your account and your products e.g. to inform you that your payment has been accepted or your order has been processed.5. Carrying out Direct Marketing
We may use your personal information, including information related to your order, such as your address, for direct marketing purposes. We may, for example, send you emails to inform you of news and updates about our products and services. This may be in the form of email, post, SMS, telephone or targeted online advertisements. Where required by law, we will obtain your consent prior to sending you such marketing information.
To protect your privacy and ensure you have control over the use of your personal information for marketing purposes, we will always give you the opportunity to "opt out" of direct marketing when you contact us in relation to a product or service or you receive any email, text or other direct marketing communication.
You have a right to prevent direct marketing of any form at any time - this can be exercised by following the opt-out link attached to each communication, by changing privacy settings within your SodaStream account or by sending an email to firstname.lastname@example.org. If you want to review or update the information you have provided us, you can click "my profile" at our website's home page, and edit the information. If you have not been asked already to provide your email address and a password, we will ask you to do it before changes are made, so as to prevent others from accessing and altering your personal information.
Based on the information we have about you, we take steps to limit direct marketing to a reasonable and proportionate level, and to send you communications which we believe may be of interest or relevance to you, based on the information we have about you.
6. Legal basis for processing personal data
2. our use of your personal data is necessary to support legitimate interests that we have as a business to provide products and services to our customers, provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights. For example, we strive to always improve our products and services in order to make them fit our customers' needs. For this reason, we process personal data such as consumption habits, device information and household composition and draw insights in relation to possible improvements; or
3. our use of your personal data is necessary to comply with a relevant legal or regulatory obligation that we have. For example, to maintain appropriate business records, to comply with lawful requests by public authorities and to comply with applicable laws and regulations or as otherwise required by law; or
4. you have provided your consent to us using your personal data for that purpose (e.g . where you provide us with marketing consents or opt in to additional services).
Where the basis of processing is your consent, you have the right to withdraw your consent, and therefore prevent that processing, at any time.
7. How we protect and store your personal data
1. Data Security
- To prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect. Some of the steps we take are: placing confidentiality requirements on our staff and service providers; destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected. SodaStream will comply with all applicable laws in the event of any breach of the security, confidentiality or integrity of your personal information that we hold and, where we consider appropriate or where required by the Privacy Act 1988 (Cth), notify you via email, text or conspicuous posting on our website in the most expedient time possible and without unreasonable delay.
- However, the security of personal information depends in part on the security of the device used to communicate with us, the security you use to protect your login information, and the security provided by your internet service provider. Where you have a SodaStream username, login or password, you are responsible for keeping this information confidential. We ask you not to share a username, login or password with anyone.
- We may retain your personal information for as long as is necessary, which depends upon the type of information and the purposes for which it may be used and disclosed by us. We will need to keep personal information for as long as is necessary to provide our products and services, and beyond such time to the extent necessary to satisfy our legal obligations (e.g . in relation to invoice retention) or for other purposes such as responding to possible disputes or complaints or for possible reactivation of subscriptions.
- In addition, we maintain a data retention policy which we apply to information in our care. Where your data is no longer required we will take reasonable steps to ensure that it is securely deleted or anonymised.
- Please note that SodaStream may retain applicant personal data submitted to it for no longer than two years after the applied position has been filled or closed. This is done so we could re-consider applicants for other positions and opportunities at SodaStream; so we could use their information as reference for future applications submitted by them; and in case the applicant is hired, for additional employment and business purposes related to his/her work at SodaStream. If you previously submitted applicant personal data to SodaStream, and now wish to access it, update it or have it deleted from SodaStream's systems, please contact us at email@example.com
8. We may share your personal data
2. with any third parties to whom the relevant SodaStream entity subcontracts all or part of its operations. The purpose of this transfer will be to help manage our business and deliver services. For instance, we may transfer your personal information to a service provider to the extent necessary to complete an order and deliver your product. Other instances may include transfers to e-marketing service providers, hosting providers and any other relevant ICT service providers. Note that we will never sell your personal information to a third party. These third parties have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us.
3. We may disclose your personal information to others where
- we are required or authorised by law to do so;
- you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
- we are otherwise permitted to disclose the information under the Privacy Act 1988 (Cth).
We may also disclose any personal information or other information obtained from or about you, to third parties in connection with a merger, acquisition, bankruptcy or sale of all or substantially all of our assets, to the extent that this is necessary for the process.
9. Transferring personal data globally
Your personal information may be transferred and processed outside your place of residence, to countries such as Israel which are subject to different standards of data protection. We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable laws and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights. To this end:
1. we will ensure that transfers within SodaStream and its affiliates will be covered by an agreement entered into by members of SodaStream Group (an intra-group agreement) which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within the Group;
2. where we transfer your personal information outside SodaStream, including to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your personal information;
3.where we receive requests for information from law enforcement or regulators, we will carefully validate these requests before personal data is disclosed.
SodaStream uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our services on an ongoing basis, and in order to provide our customers with a better experience. For example, thanks to these technologies, we are able to maintain and keep track of our customers' preferences and authenticated sessions, to better secure our services, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our services.
We use the following cookies on our website:
1. necessary cookies
Necessary cookies are essential and help you navigate our website. This helps to support security and basic functionality and are necessary for the proper operation of our website, so if you block these cookies we can't guarantee your use or the security during your visit
2. functionality cookies
3. performance cookies
Performance cookies help us to understand the behaviour of users of our website. This allows us to continuously improve our website to provide the best information in support of our project aims. These cookies are also used to help us understand how effective our website is. For instance these cookies tell us which pages visitors go to most often and if they get error messages from web pages.
All of the Cookies are managed by third parties, and you may refer to the third parties' own website privacy notifications for further information. In particular, we use Google Analytics, which allow us to assess how you and other web users use our website, and this information is essential in helping us to continuously improve our website's functionality. They can be preserved from 30 minutes to two years. The information generated by these cookies about your use of our website (including your IP address) will be transmitted to and stored by Google Inc.
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11. Your rights in relation to your personal data
Individuals in Australia have the following rights under the Privacy Act 1988 (Cth):
- to request that we provide you with a copy of your personal information that we hold
- to request that we correct any errors in your personal information, to ensure that the personal information we hold about you is accurate, up-to-date, complete, relevant and not misleading. Note that you may also correct, update or remove certain parts of your personal information by yourself, or completely deactivate your SodaStream account, through your account settings; and
- to lodge a complaint with the Office of the Australian Information Commissioner (OAIC).
We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.12. Changes to this Privacy Notice
We will review your complaint and endeavour to respond to you as soon as possible. If you are unhappy with our response to your complaint, you have the right to make a complaint to the OAIC. Details of how to contact the OAIC are provided on its website at www.oaic.gov.au.