Privacy Policy (OLD ONE)
1. WHO WE ARE
“We”, “us” or “our” means The Vita Coco Company Inc., a Delaware corporation with its principal place of business located at 250 Park Avenue South, Floor 7, New York, NY 10003, and all brands hereunder: Vita Coco, Ever & Ever, Runa, etc. For the purposes of certain data protection laws, including the EU General Data Protection Regulation (“GDPR”) and the UK General Data Protection Regulation (“UK GDPR”), we act as controller for the personal data we gather through your use of our website.
2. WHAT WE COVER IN THIS PRIVACY POLICY
Your privacy is important to us, so we’ve developed this Privacy Policy (the “Privacy Policy” or “Policy”), which sets out how we collect, disclose, transfer and otherwise use (collectively, “process”) the personal data or personal information that you share with us on our website, vitacoco.com (the “Service”). Please take a moment to read through this Policy in its entirety.
If you have any questions, concerns or complaints regarding this Privacy Policy or our processing of your personal data or you wish to submit a request to exercise your rights as set out in Section 5, you can do so by contacting us via e-mail: privacy@vitacoco.com.
This Privacy Policy was last revised on October 21, 2021.
3. HOW WE COLLECT, USE AND DISCLOSE YOUR PERSONAL DATA
Personal data is defined as any information relating to an identified or identifiable natural person. Identifiable refers to identifiers (such as name, identification number, location data, etc.), that can be used to directly or indirectly identify a natural person.
The personal data we collect, is collected and used for the purposes and subject to the lawful bases listed hereunder:
- In the event you use the contact form on our website, we will use your personal data in order to reply to your query, via e-mail or telephone. If the GDPR/UK GDPR applies, and (i) your query is related to a service we are providing to you, we process your personal data in order to perform our contract with you or (ii) where your query is general, on our legitimate interests to run a successful business and maintain a relationship with you.
- In the event you create a profile on our website or you provide us with transaction data, we collect your personal information in order to save such information, to provide you with our services and permit us to receive your information or to contact you. If the GDPR/UK GDPR applies, we process your personal data to perform our contract with you and for receiving information and contacting you in this context. Otherwise, we rely on our legitimate interests to run a successful business and maintain a relationship with you.
- In the event you register for our newsletter, your e-mail address will be used in order to send you our newsletters, which may include invites to events, seminars, etc. organized by us. Where required under local laws in the EEA/UK, we rely on your consent to do so.
- We Process your personal data for the purpose of supporting the website, mobile applications, advertising experience, and enhancing your user experience, which includes ensuring the security, availability, performance, capacity and health of these systems. If the GDPR/UK GDPR applies, we rely on our legitimate interests in running a successful business and, where required by law, on your consent.
- We Process your personal data to enforce or exercise any rights that are available to us based on the applicable law, such as use for the establishment, exercise or defense of legal claims, to enforce any applicable terms and conditions and to protect or defend our rights, the rights of our users and others.
We Process the following categories of personal data:
- Contact data: in the event you make use of the contact form, you will be asked to provide the following information: name, address, e-mail address, phone number, and any personal data that you choose to provide in the designated blank field (please do not provide us with any special/sensitive information, such as health information, information pertaining to criminal convictions, or credit card/account numbers). This is information that is provided directly by you.
- Profile data: If you create an account on our website, we collect the following data: name, telephone number, e-mail address, address, country, company name, job title, industry. This is information that is provided directly by you.
- Transaction data: We collect personal data relating to transactions that you make through the website, including your “contact data”, payment information and the goods and/or services purchased. This is personal data provided directly by you.
- Identifiers such as name: We collect personal data relating to your access request to The Vita Coco Company Inc. resources, sales inquiry, partner inquiry, subscription to our newsletter: name, telephone number, e-mail address, shipping and billing address, country. This is personal data provided directly by you.
- Customer Records Information such as credit/debit card number used to pay for goods.
- Characteristics of Protected Classifications such as age to determine permitted use of our services, including for permitting payments on our website.
- Commercial Information such as your purchase history.
- Internet or other Electronic Network activity information such as Usage Data: We collect personal data regarding your activities on our website: IP address, device ID and type, referral source, language settings, browser type, operating system, geographical location, length of visit, page views, or information about the timing, frequency and pattern of your service use. This information may be aggregated and used to help us provide more useful information regarding the use of our website. In the event the usage data is completely anonymized (and can therefore not be traced back to you as an individual), this will not be considered personal data for the purpose of this Privacy Policy. This is personal data that is collected through your use of the website.
- Geolocation data such as to determine the applicability of regional legislation permitting the purchase of certain products based on your device’s location.
- Professional or employment-related information such as employer or workplace to determine any logistical requirements for shipping or delivery.
- Inferences such as product flavor or fragrance preference.
Note that some of the above categories of personal data will be required in order to provide you with our services, by not providing such categories of personal data, we may not be able to fulfill your order.
We will share your personal data with third parties for our legitimate business purposes or to perform our contract with you, as noted below:
- Identifiers such as name, shipping address, or billing address. For example, if we use a 3rd party carrier to deliver your order.
- Customer Records Information such as credit/debit card number used to pay for goods. For example, if we use a 3rd party payment processor.
- Commercial Information. For example, your order detail will be required for a 3rd party logistics provider to fulfill your order.
- Internet or other Electronic Network activity information such as your use of our website in terms of browsing and search history. For example, 3rd party monitoring services may be used to ensure operational effectiveness of our services and website as well as the following service providers:
- Candyspace as a website builder
- Lunar Solar Group as website builder
- Interesting Development as website builder;
- Amazon Web Services (AWS) as website hoster;
- Shopify as website hoster and eCommerce transactor; and
- Wordpress as website hoster.
- Professional or employment-related information. For example, if you place a subscription order for your work, office, etc., your employment-related information, such as work address, will be required by a 3rd party delivery and logistics provider, including, but not limited to Resurge LLC, Ingram Micro, United States Postal Service, United Parcel Service, and Federal Express.
- We will share your personal data with professional advisors functioning as service providers such as auditors, law firms, or accounting firms.
- We will share your personal data with regulators, law enforcement agencies, public authorities, or any other relevant organizations: (i) in response to a legal obligation; (ii) if we have determined that it is necessary to share your personal data to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries; (iii) to protect the interests of, and ensure the safety and security, of us, our users, a third party or the public; (iv) to exercise or defend legal claims; and (v) to enforce our terms and conditions, other applicable terms of service, or other agreements.
- We will share your personal data with companies within our corporate family.
- We will share your personal data with a prospective buyer, seller, new owner, or other relevant third party as necessary while negotiating or in relation to a change of corporate control such as a restructuring, merger, assets or shares sale or purchase, other business transaction or re-organization or in connection with bankruptcy.
4. RETENTION OF YOUR DATA AND DELETION
Your personal information will not be kept for longer than is necessary for fulfilling the processing purposes listed in this Policy. Generally, we retain your information for as long as we have a relationship with you and, after our relationship with you has ended, if there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax, accounting and/or billing and collection obligations, to resolve disputes, enforce our policies and establish, exercise and defend our rights and any claims. We broadly retain information for approximately 3 years after our relationship with you has ended, but this term may differ, based on our data retention policies and applicable laws.
If you stop using our services or if you delete your account with us, we will store your information in an aggregated and anonymized format; we may use this information indefinitely without further notice to you.
5. CALIFORNIA RESIDENTS
We collect certain “personal information” as defined by the California Consumer Privacy Act (“CCPA”). In the past 12 months, we have collected such personal information described in Section 3 above. We do not “sell” such personal information about you to third parties and have not done so in the past 12 months. However, we share certain such personal information with the third parties, and for the purposes, described in Section 3 above.
If you are a California resident, you may be able to exercise certain rights in relation to your personal information:
Right to Know. You may have the right to know and see what data we have collected about you over the past twelve months, including:
- The specific pieces of personal information we have collected about you;
- The categories of personal information we have collected about you;
- The categories of sources from which the personal information is collected;
- The business or commercial purpose for collecting your personal information; and
- The categories of third parties with whom we have shared your personal information.
Right to Delete. You may have the right to delete the personal information we have collected from you (and direct our service providers to do the same).
Other Rights. You may be able to request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year. You may also have the right not to be discriminated against for exercising any of the rights listed above.
Exercising Your California Privacy Rights. To submit a request, please contact us using one of the following methods:
- Email us at privacy@vitacoco.com. Please include your full name, email address and phone number associated with your use of the Service.
- Send us a letter to The Vita Coco Company, Inc., Attn: Privacy, 250 Park Ave. S., 7th Floor, New York, NY 10003 with your full name, email address and phone number associated with your use of the Service.
Only you, or someone that you authorize to act on your behalf, may make a request to know or delete personal information about you. An authorized agent may make a request by providing written permission signed by you. We may need to confirm your identity before processing your request by asking you for additional information, such as a government issued ID or date of birth.
6. UK AND EEA USER RIGHTS
If you are located in the EEA or the UK, you have certain rights in relation to your personal data:
- Access: You have the right to access personal data we hold about you, how we use it, and who we share it with.
- Portability: You have the right to receive a copy of the personal data we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
- Correction: You have the right to correct any of your personal data we hold that is inaccurate.
- Erasure: In certain circumstance, you have the right to delete the personal data we hold about you.
- Restriction of processing to storage only: You have the right to require us to stop processing the personal data we hold about you, other than for storage purposes, in certain circumstances.
- Objection: You have the right to object to our processing of your personal data.
- Objection to marketing: You can object to marketing at any time by opting-out using the unsubscribe/ opt-out function displayed in our communications to you.
- Withdrawal of consent: Where we rely on consent to process your personal data, you have the right to withdraw this consent at any time by emailing us at privacy@vitacoco.com.
Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, where there are overriding public interests or where we are required by law to retain your personal data.
To exercise any of these rights, please contact us at privacy@vitacoco.com with specific attention to the Data Protection Officer. We will respond to requests to exercise these rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances).
If you consider that our processing of your personal data infringes data protection laws, you have the right to lodge a complaint with a supervisory authority. You may do so in the EEA member state of your habitual residence, your place of work or the place of the alleged infringement or, in the UK, you can submit a complaint to Information Commissioner’s Office (ICO).
7. INTERNATIONAL TRANSFERS
As we are a company located in the United States (“US”), please note that your personal data will be transferred and stored in the US in order to provide our services to you, or if applicable, we will obtain your consent.
To the extent the GDPR or the UK GDPR apply, for transfers of data to third parties located outside the EEA or the UK, we rely on the European Commission’s model contracts for the transfer of personal data to third countries (the “Model Clauses”), or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their personal data. Please contact our Data Protection Officer at privacy@vitacoco.com should you wish to examine a copy of the Model Clauses.
8. SOCIAL MEDIA PLUGINS AND COOKIES / DO NOT TRACK
We use cookies and other tracking technologies (collectively referred to as “cookies”) on our website. Cookies are small text files that uniquely identify your browser or device. The cookie file is stored on your browser on your computer or mobile device. When you return to that website (or visit websites that use the same cookies) these websites recognize the cookies and your browsing device. Cookies have many different functions, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience or providing us information about how users navigate through our website.
Cookie types:
- Session Cookies: Session cookies keep track of you or your information as you move from page to page within the website and are typically deleted once you close your browser.
- Persistent Cookies: Persistent cookies reside on your system and allow us to customize your experience if you leave and later return to the website. For example, persistent cookies may allow us to remember your preferences.
Cookie purposes:
- Strictly necessary cookies: These cookies are essential to provide you with our website and its features. Without these cookies, our website would not function properly.
- Functional cookies: Functional cookies record information about choices you've made and allow us to tailor our website to you. When you continue to use or come back to our website, we can provide you with our services as you have asked for them to be provided. These cookies allow us to save your location preference if you have set your location, remember settings you have applied, such as layout, text size, preferences, and colors and store accessibility options.
- Analytics cookies: We use analytics cookies to analyze how our website is accessed, used or is performing in order to provide you with a better user experience and to maintain, operate and continually improve our website.
- Advertising and targeting cookies: We allow third parties, including advertising companies, to place advertising cookies on our website. These cookies enable such third parties to track your activity across various sites where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the Internet. These cookies also allow us and third parties to know whether you have seen an ad or a type of ad, and how long it has been since you've last seen it. This information is used for frequency capping purposes, to help tailor the ads you see, and to measure the effectiveness of ads.
- Social media cookies: We make use of social media plugins to direct you to our social media channels and to allow you to interact with our content. These social media channels are Facebook, Instagram, LinkedIn, Twitter, Google+, Vimeo and Pinterest. In the event you click on the plugins, the social media service provider may collect personal data about you and may link this information to your existing profile on such social media. We are not responsible for the use of your personal data by such social media service providers. For your information only, please find below links to the services providers’ privacy policies (note these links may be changed from time to time by the relevant service provider):
- Facebook: http://facebook.com/about/privacy;
- Instagram: https://help.instagram.com/155833707900388;
- LinkedIn: http://linkedin.com/legal/privacy-policy;
- Twitter: http://twitter.com/privacy;
- Google+: https://www.google.com/intl/en/policies/privacy/;
- Vimeo: https://vimeo.com/privacy;
- Pinterest: http://policy.pinterest.com/en/privacy-policy.
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Controlling or deleting cookies:
We use cookies on this website to make sure you can use the website easily and enjoy it. Some of the cookies are strictly necessary and we cannot provide our services and allow navigation of our website without them. There are other types of cookies (as described above) that are not strictly necessary which you can choose to opt-in to or, if you have already opted-in, you can choose to opt-out off.
When you visit our website for the first time, we will provide you with a notice which lets you know how we use cookies, why we use them and how you can change which cookies you accept. You can opt out of cookies at any time, however your experience on our website may not be as good as it could otherwise be. To opt out of tracking by Google Analytics, visit https://tools.google.com/dlpage/gaoptout. To opt out of seeing targeted online ads from us and other participating companies, visit www.youronlinechoices.com or www.allaboutcookies.org. Please note that this list will contain more networks than those used on our Website. Please note this does not mean that you will see less advertising when you visit our Website, the only effect is that the advertising will be less relevant to you.
In addition to the above, you may be able to configure your browser settings to use the website without some cookie functionalities. You can delete cookies manually or set your browser to automatically delete cookies on a pre-determined schedule. For example, in the Internet Explorer menu bar, select: Tools Internet OptionsBrowsing HistoryDelete to view manual and automatic options.
Do Not Track Signals:
Some web browsers may transmit Do Not Track signals to websites with which the browser communicates, telling the site not to follow its online movements. Because of differences in how web browsers interpret this feature, it is not always clear whether website users intend for these signals to be transmitted, or whether they are even aware of them. Therefore, we currently do not respond to such Do Not Track signals.
9. AMENDMENTS TO THE PRIVACY POLICY
We may revise this Privacy Policy, from time to time, in which case we will update the “last revised” date from Section 2 above. You will always be able to consult the most recent version of the Privacy Policy on the website. Please check back regularly to keep informed of any updates or changes.