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SODASTREAM - PRIVACY STATEMENT

Notice last updated: 9.2.2020
  1. 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").

    2. SodaStream is committed to the handling of personal information in accordance with applicable laws, including the Australian Privacy Principles set out in the Privacy Act 1988 (Cth). To better protect your privacy, we provide this policy (“Privacy Policy”) explaining our information practices and the choices you can make about the way your information is collected and used.

    3. To make this notice easy to find, we make this Privacy Policy available on our homepage and at every point where personal information may be collected, such as during purchase on our website or when joining our customer database for newsletter content.

    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.

    5. If you read and fully understand this Privacy Policy, but remain opposed to our privacy practices, you must immediately leave our website, and avoid or discontinue all use of any of our Services. Where you have read this Privacy Policy but would like further clarification, please contact us at privacy@sodastream.com.

  2. Important information

    1. The purpose of this Privacy Policy is to provide you with clear explanation of what personal information we collect, when, why and how we collect, use and share your personal data and it explains your statutory rights. This Privacy Policy is not intended to override the terms of any contract you have with us, nor any rights you might have under the Australian Privacy Principles set out in the Privacy Act 1988 (Cth).

    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 privacy@sodastream.com.

    3. Note that our website contains links to third party websites which we are not responsible for. Please review the privacy policies of such third party websites should you visit these websites. This Privacy Policydoes not address the privacy or information practices of any third parties.

    4. Our website uses cookies and other tracking technology to automatically collect certain data concerning its interactions with visitors. Some of this information may include personal data. We explain more about the information we collect using cookies and tracking technology in paragraph 10.

  3. What information do we collect and how do we collect it?

    1. Personal information is collected when you voluntarily submit it through a website form or if you register with or use one of our website or online services. Our website automatically collects certain data concerning its interaction with visitors that facilitate operation, management and planning. Some information that may constitute personal information (such as your browser type, operating system, IP address, domain name, number of times you visited the website, dates you visited the website, date and time of an online request, the time required to download information you requested, error codes generated while your browser is in contact with our website and the amount of time you spent viewing the website) may be collected via cookies and other tracking technologies, all on an anonymised basis. Aggregate information (such as how many times visitors log onto our website) may also be collected. We explain more about our use of cookies and tracking technologies in paragraph 10.

    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.

    5. If you engage with us through social media e.g . Water Blog, Recipe Site, Facebook, Pinterest, Twitter, we collect login information and any personal information you voluntarily provide, such as opinions in blog or recipe entries, or messages you post on our social media pages. If you upload content, including your personal information, to a social network and then tag our website, your submission will be subject to that social network's terms of use and privacy policy, even where you post on an official SodaStream page on the social network. We do not have control over these terms of use and privacy policies, and have not reviewed their adequacy. You should therefore review these before submitting any personal information.
    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 also use this information for customer management purposes, to maintain our relationship with you, with a view to providing you with a stellar customer experience.

    2. To verify your identity

      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.

    3. For internal business purposes such as:

      1. to improve our products in order to make them fit for our customers' needs and to draw insights in relation to possible improvements;
      2. 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
      3. to track any fraudulent activities and other inappropriate activities and monitor content integrity on our website.
    4. To process job applications

      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.

    1. 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.

    2. 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 privacy@sodastream.com. 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.

    3. 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:

    1. We will only collect, use or share your personal data for the purposes set out in this Privacy Notice where we are satisfied that:

      1. our use of your personal data is necessary to perform a contract or take steps to enter into a contract with you. For example, in order to provide our product and our services it will be necessary for us to process certain personal data such as your address, phone number, identification data and payment data to create your user account or fulfil your order. Also, we carry out this processing for the purpose of knowing our customer and maintaining our relationship with you, with a view to providing a stellar customer experience; or

      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

      1. 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.

      2. 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.

    2. Data Retention

      1. 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.

      2. 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.

      3. 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 privacy@sodastream.com.

  8. We may share your personal data

  9. SodaStream may share your personal information with third parties (or otherwise allow them access to it) only in the following manners and instances:

    1. to other SodaStream affiliates for the purposes mentioned in this Privacy Policy.

    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:

      1. we are required or authorised by law to do so;

      2. you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or

      3. we are otherwise permitted to disclose the information under the Privacy Act 1988 (Cth).

      4. 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.

  10. Transferring personal data globally

  11. Your personal information may be transferred and stored 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; or

    3. where we receive requests for information from law enforcement or regulators, we will carefully validate these requests before personal data is disclosed.

    where we receive requests for information from law enforcement or regulators, we will carefully validate these requests before personal information is disclosed.

  12. Use of Cookies and Other Tracking Technologies

  13. 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.

    Please note that third party services placing cookies or utilizing other tracking technologies through our services may have their own policies regarding how they collect and store information. Such practices are not covered by our Privacy Policy and we do not have any control over them.

    1. Cookies

      1. Our website uses cookies, web beacons and similar technologies ("Cookies") to track information provided to us by your browser when you use our website. Cookies are small text files containing small amounts of information which are downloaded and may be stored on any of your devices that enable internet usage e.g. your computer, smartphone or tablet - like a memory for a web page. We use several different types of cookies. We use the following cookies on our website:

    2. 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

        Functionality cookies are used to provide you the best user experience. These cookies are, for instance, used to personalise content for you in line with your location. It also allows our website to remember choices made (like turning off use of cookies or which location you have previously selected) to provide more personal features.

      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.

      4. 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 on servers in the United States.

    3. Control your cookie settings:

      Once you have given us your agreement to the use of cookies, we shall store a cookie on your computer or device to remember this for next time. Internet browsers allow you to change your cookie settings, for instance to block certain kinds of cookies or files. You can therefore block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies, you may not be able to access all or parts of the website, due to the fact that some may be functionality cookies. further information about deleting or blocking cookies, please visit: http://www.allaboutcookies.org/manage-cookies/

  14. Your rights in relation to your personal data

    1. Individuals in Australia have the following rights under the Privacy Act 1988 (Cth):

      1. to request that we provide you with a copy of your personal information that we hold;

      2. 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

      3. to lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

    2. 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.

  15. Changes to this Privacy Notice

  16. We may update and change this Privacy Policy from time to time, to keep it up to date with legal requirements and the way we operate our business. Please regularly check these pages for the latest version of this Privacy Policy .

  17. Contact information

    1. If you would like to contact us, including if you have any questions about this Privacy Policy, wish to exercise any of your rights as described in section 11, or make a complaint regarding your privacy, you can contact us at: email address: privacy@sodastream.com

    2. 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.

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