Privacy Policy

# Legal Policies

Privacy Policy

Updated: August 16, 2023

Your privacy is important to Gillette Pepsi Companies, Inc. (hereafter GPC) (“we,” “us,” and “our”).  This Privacy Policy (“Privacy Policy”) describes the information, data collection, and other privacy practices for our websites currently located at:

Primary corporate website:  www.gpcbeverage.com 

Hiring/Recruiting:
https://recruiting.paylocity.com/recruiting/jobs/All/e7160444-4bba-4bb8-a246-179fb24897b7/Gillette-Pepsi, and

Pepsi Portal/Ordering:
https://login.vtinfo.com/adfs/oauth2/authorize/?client_id=deeb6927-e324-44e8-b7d8-7de363af8243&redirect_uri=https://apps.vtinfo.com/retailer-portal/openid&resource=https://vtinfo.com&response_type=code&scope=email%20profile%20vtinfo.itemcatalog.distributor.read%20vtinfo.beverage.retailer.pricing%20vtinfo.sso.admin.readwrite%20vtinfo.client%20vtinfo.pay.stripe.sellers.read%20vtinfo.ras.mws.readwrite&state=ABBU1G

 (collectively, the “Sites”), including, without limitation, what type of information is gathered and tracked, how the information is used, and with whom the information is shared.  As described below, this Privacy Policy also applies to your other interactions with us, such as when you enter promotions, purchase products or services, sign up for a newsletter or provide information to us.

By visiting our Sites or submitting your Personal Information (as defined below) to us by any means, you are giving your consent to our collection, use and disclosure of your Personal Information as described in this Privacy Policy.  If you do not agree to the terms of this Privacy Policy, please exit our Sites, and do not provide Personal Information to us.

If you are a resident of California, you have special rights under the 2018 California Consumer Protection Act (CCPA). You can read more about your rights here: California Privacy Rights.


What Information We Collect:

This Privacy Policy applies to all information collected by or submitted to us (or carefully selected third parties acting on our behalf), including Personal Information (as defined below). “Personal Information” is data that reasonably can be used to identify or describe an individual, such as your name, e-mail address, physical address, phone number(s), and credit card information.  You do not need to provide us Personal Information to simply browse our Sites.  In addition, we use web analytics tools to gather anonymous, aggregated demographic information by tracking IP addresses and other types of Traffic Data (as defined below).  We may use this anonymous, aggregated demographic information and share it with third parties to better understand users’ activity on our Sites and provide services to our visitors.  To learn more about our collection and use of Traffic Data, see the “Traffic Data” section below.

To see all of the categories of Personal Information we collect, see Appendix A of this policy below.

We may collect Personal Information and Traffic Data when:

·       you make purchases of products or services;

·       you request support for the products or services;

·       you create an account on one of our Sites;

·       you request information or materials (e.g. newsletters);

·       you participate in surveys and evaluations;

·       you participate in promotions, contests or giveaways, which we may offer from time to time; or

·       you submit questions or comments to us.

The types of Personal Information and Traffic Data collected may include (but are not limited to), as applicable:

·       your first and last name;

·       your business name;

·       your home, business, billing, or other physical address (including street name, name of a city or town, state/province, postal code);

·       your e-mail address;

·       your telephone number;

·       any other identifier that permits us to make physical or online contact with you.


Use of Your Information: 

Generally

We collect and use your Personal Information and Traffic Data to operate and improve the Sites and deliver the services or carry out the transactions you have requested. These uses may include providing you with more effective customer service; making the Sites easier to use by eliminating the need for you to repeatedly enter the same information; performing research and analysis aimed at improving our products, services, and technologies; and displaying content and advertising that are customized to your interests and preferences.

We also use your Personal Information and Traffic Data to communicate with you. We may send certain mandatory service communications such as welcome letters, newsletters, information on technical service issues, and security announcements. We may also contact you to inform you of other products available from us.

We may share your information within our divisions to optimize communications and promotions. This involves sharing information about browsing and purchasing behavior across our different websites and targeting promotions and communications accordingly.

Sale or Acquisition of Assets

If we or substantially all our assets are acquired, your Personal Information will be one of the transferred assets.  If we sell a business, we will include provisions in the selling contract requiring the purchaser to treat your Personal Information in the same manner required by our Privacy Policy in effect at that time.  The provisions of this paragraph will apply also if we are sold as a part of bankruptcy proceedings.

If we purchase a business, the Personal Information received with that business will be treated in accordance with our Privacy Policy in effect at that time, so long as it is practicable and permissible to do so.

Use by Third Parties

From time to time, we may use your Personal Information and Traffic Data: (a) if we need to respond to valid legal process, including, but not limited to, a search warrant, subpoena, or court order, and any other instance when we believe we are required to do so by law; or (b) if we deem it necessary to disclose Personal Information or Traffic Data, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request, or to protect our rights or interests.  We may also exchange Personal Information with other companies and organizations for credit fraud protection and risk reduction.

We may share Personal Information and Traffic Data with companies working on our behalf and to our affiliated companies.  In addition, some our services may be co-branded or offered in conjunction with another company. If you register for or use such services, both us and the other company may receive information collected as part of the co-branded services.

In some cases, we use contractors to collect, use, analyze and otherwise process information on its behalf.  We may also allow carefully selected partners to participate in limited marketing campaigns solely to promote our products and services to you.

If you request something from the Sites (for example, a product or specific marketing materials), we will use the information you provide to fulfill your request. To help us do this, we may share information with others, such as our business partners, financial institutions, shipping companies, and postal or government authorities (e.g., Customs authorities) involved in fulfillment. As part of a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes, which may require us to engage third-party service providers.

We occasionally hire other companies to provide limited services on our behalf, such as handling the processing and delivery of mailings, providing customer support, hosting websites, processing transactions, or performing statistical analysis of our services. Those companies will be permitted to obtain only the Personal Information they need to deliver the service. They are required to maintain the confidentiality of the Personal Information and are prohibited from using it for any other purpose.

We do not endorse specific third parties or their goods or services, regardless of whether such third parties offer goods or services on the Sites from time to time.  Any relationship between you and such third parties will be governed exclusively by the terms offered by the third party and agreed to by you.  If you provide these third parties with any Personal Information or other information, their use of such information will be subject to their privacy policies, if any, and will not be governed by this Privacy Policy.  In addition, if you accept third-party goods or services advertised on the Sites, a third party may be able to determine that you have a relationship with us (e.g., if the offer is made only through the Sites).

Except as set forth herein, unless you have provided consent, we will not (a) sell, rent, or lease your Personal Information to third parties, and (b) disclose your Personal Information to third parties for their own marketing purposes.

To see all of the categories of Personal Information we share, view Appendix A of this policy below.

Your Choices:

We provide several ways for you to ‘opt-out’ of receiving additional information from us or having us provide your Personal Information to our partners. We may offer you these choices at the time you give us your information.

If you do not wish to continue receiving certain marketing materials (e.g., email messages), you can opt-out of receiving these materials by following the unsubscribe instructions provided in the materials. This option does not apply to communications primarily for the purpose of administering orders, contracts, support, product safety warnings, software updates, or other administrative and transactional notices.

We may work with third parties, such as Google Ads Manager, that collect and use information about your website and mobile app usage over time and across our and non-affiliated websites and mobile apps including on different devices and browsers.  These partners may use cookies, web beacons, pixels, and other similar technology to collect this information, and use it to infer your interests and deliver relevant advertising to your browser or device, and browsers or devices associated with it.  This activity is called interest-based advertising.  To learn more information about interest-based advertising, and to opt out of interest-based advertising on your browser from companies that participate in industry self-regulation, US users can visit www.aboutads.info/choices.  To opt out of interest-based advertising from participating companies for mobile apps, you can visit www.youradchoices.com/appchoices and download the appropriate version of AppChoices for your device.

When you exercise choice through these tools, you will still receive advertising, but that advertising may be less relevant to you.  After you make your choices, data will no longer be collected from your browser or device for interest-based advertising on that browser or device, or associated browsers or devices.  Additionally, data from those associated browsers and devices will not be used for interest-based advertising on the browser or device for which you made your choices.  Data may still be collected for other purposes, such as analytics, reporting, and research.  If you delete your cookies, reset your mobile identifier, or use multiple browsers or devices, you will need to re-register your opt-out choices again.

Some devices and browsers support a “Do Not Track” (or DNT) feature, a privacy preference that you can set in certain web browsers, which is intended to be a signal to websites and services that you do not wish to be tracked across different websites or online services you visit. Please note that we cannot control how third party websites or online services you visit through our website respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices.

How to Update Your Information:

Here are some ways you can modify the contact information that you have provided to us:

·       Email Newsletters: Should your email address change, you may manage your subscription by unsubscribing to our newsletter and re-subscribing with your new email address.

·       Generally: At any time, you may update your information by e-mailing us at marketing@gillettepepsi.com.

Please note that we reserve the right to remove a user from our mailing list at any time, in our sole discretion.

Safeguarding Your Personal Information:

We recognize industry standards and employ security safeguards to protect your Personal Information from unauthorized access and misuse. We use the most accurate and current information you provide to process your request.  We store your Personal Information in secured third-party databases, such as those owned and operated by Constant Contact, an email service provider.  Browsers offer varying degrees of security, particularly regarding encryption. Even the same version of a browser can come with different levels of encryption. For your protection, make sure your browser is set and configured to support Secure Socket Layer (“SSL”) 2.0/3.0 and employs 128-bit encryption. All acceptable browsers do provide detailed information on security levels in “Properties” or “Document Information” from the browser’s menu bar. See your browser’s “Help” tab or documentation for more information.

Unfortunately, the transmission of information via the Internet is not completely secure.  Although we do our best to protect your information, we cannot guarantee the security of any information you transmit to our Sites.  Any transmission of information, including Personal Information, is at your own risk.  We are not responsible for circumvention of any privacy settings or security measures contained on this Sites.

Enforcement:

We regularly review our compliance with this Privacy Policy. Please feel free to direct any questions or concerns regarding this Privacy Policy or our treatment of Personal Information by contacting us at the link indicated below.

Traffic Data:

Generally

Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes and for improving your experience on the Sites.  When you visit our Sites, we may automatically track and collect the following categories of information: (1) web beacons; (2) IP addresses; (3) log files; (4) domain servers; (5) types of computers accessing the Sites; and (6) types of web browsers used to access the Sites (collectively “Traffic Data”).  We also use “cookies” to collect Traffic Data to customize content specific to your interests and make your navigation of the Sites easier during subsequent visits.

Cookies and Browser Information

We may use cookies for a variety of purposes. A cookie is a name for tokens of information that our Sites may provide to your browser while you are at our Sites.  Cookies are stored on your device’s hard drive and once placed there, the cookie will remain until you remove it.  We may use cookies to help us keep track of the items that you place in your portal cart and to better understand our Sites’ usage in the aggregate so that we know what areas of our Sites users prefer. We may also use temporary or “session” cookies to help you learn more about and/or order our services.  If you simply want to browse, you do not have to accept cookies from our Sites. Most browsers are defaulted to accept and maintain cookies. These cookies are not tied to your Personal Information.

In the event we elect to become an ad publisher, third party vendors, including Google, may use cookies to serve ads to you while you are using our Sites based on your prior visits.  We do not have access to or control over these cookies, and we disclaim liability for the actions of all third-party vendors.  You may opt out of Google’s use of cookies by visiting the Google advertising opt-out page.

Web Beacons

Web beacons (also known as “web bugs”) are small strings of code that provide a method of delivering a graphic image on a web page or in an e-mail message for the purpose of transferring data.  We may use web beacons (or clear GIFs) on our Sites or include them in the e-mail messages we send you for many purposes, including site traffic reporting, unique visitor counts, advertising e-mail auditing and reporting, and personalization.  Information gathered through web beacons may be linked to your Personal Information.

IP Addresses and Log Files

An Internet Protocol (“IP”) address is a number assigned to each computer on a network to identify your computer every time you log on to the Internet.  We may keep track of IP addresses to troubleshoot technical concerns and to maintain the safety and security of our Sites.  In addition, we may use IP addresses to analyze trends, administer our Sites, track traffic patterns, and gather demographic information for aggregate use.

Please be aware that, with or without cookies, our Sites keep track of usage data, such as the source address from which a page request originates (i.e., your IP address, domain name), date and time of the page request, the referring web site (if any), and other parameters in the URL (e.g., search criteria). We may use this data to better understand our Sites’ usage in the aggregate so that we know what areas of our Sites’ users prefer (e.g., based on the number of visits to those areas). This information is stored in log files and may be used for aggregated and statistical reporting. It is not attributed to you as an individual (i.e., log files are not associated with any specific user, computer, or browser).

Google Analytics

We may use Google Analytics or another website reporting tool to provide analytics services as described above.  To learn more about how Google Analytics collects and processes data and the choices Google may offer to control these activities, you may visit https://support.google.com/analytics/answer/6004245.  To opt out of Google Analytics you may visit https://tools.google.com/dlpage/gaoptout/.

Online Marketing and Automation Platforms

We may we utilize an online marketing platform to help us make informed decisions about our Sites’ layouts, content, offerings, and advertising.  In the event we choose to do so, we will update this policy to let you know how that platform collects and processes data.

Links to Other Sites:

If our Sites provide links to third-party websites. You should review their privacy policies to learn more about what, why, and how they collect and use Personal Information and Traffic Data.  Please be aware that these websites are not under our control, and we have no responsibility for the privacy practices of such other websites.  This Privacy Policy applies solely to information collected by our Sites.  We make no guarantees about the accuracy, currency, content, or quality of the information provided by such third-party sites, and we assume no responsibility for unintended, objectionable, inaccurate, misleading, or unlawful content that may reside on those sites.

For avoidance of doubt, if we provide links to social media platforms, such as Facebook or Twitter, and you choose to visit those websites through our links, please note that the information you post, transmit or otherwise make available on those websites may be viewed by the public. We do not control user-posted content on social media homepages and are not responsible for any third-party use of your information that you have posted, transmitted, Por otherwise made available there.


Your California Privacy Rights:

This section applies solely to all visitors, users, and others who reside in the State of California (“CA Consumers”) and is presented in compliance with the California state laws, including the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning when used in this notice. References to “you” and “yours” in this Notice are directed to CA Consumers only.

We do not share Personal Information with third parties for their own direct marketing purposes without your consent. California residents under 18 years old, in certain circumstances, may request and obtain removal of Personal Information or content about you and posted on our Sites. Please be mindful that this would not ensure complete removal of the content posted on our Sites by you.

Under the California Consumer Privacy Act or CCPA, and subject to exceptions, California residents have certain rights regarding their data, including:

·       The right to know the categories of Personal Information we’ve collected and the categories of sources from which we got the information.

·       The right to know the business purpose for collecting Personal Information.

·       The categories of third parties with whom we share that Personal Information.

·       The right to access the specific pieces of Personal Information we’ve collected and the right to delete your information.

·       The specific pieces of Personal Information we collected about you.

·       The right to opt out of having your Personal Information sold. GPC does not sell your personal information. However, we support the CCPA by allowing California residents to opt out of any future sale of their Personal Information to third parties, as we understand that term to be defined by the CCPA and its implementing regulations.

California residents also have the right to not be discriminated against if they choose to exercise their privacy rights. We will not discriminate against you for exercising any of your California privacy rights and we will not deny you goods or services, charge you a different price, or provide you with a lesser quality of goods or services if you exercise any of those rights.

To see the categories of Personal Information we’ve collected, the categories of sources from which we got the information, the business reasons for collecting this Personal Information, and the third parties with home we may share that Personal information with, please view Appendix A to this policy below.

Exercising Your California Rights

·       To submit a request, please email marketing@gillettepepsi.com and use the subject line “California Consumer Privacy Act Request”. In the body, please include whether you would like to know or delete your personal information.

·       You may also submit a request by sending a letter to the following address:

GPC
ATTN: California Privacy Rights
P.O. Box 998

La Crosse, WI 54602-0998

·       In order to verify requests and the information in it, you must provide, at a minimum, your name and an email address and respond to a confirmation email that will be sent to that address. We may ask that you provide a photo of an official government issued ID.

·       Only you, or a designated authorized agent (someone legally authorized to act on your behalf and with written permission), may make a verifiable consumer request related to your Personal Information

Sales of Personal Information / Do Not Sell My Personal Information

GPC does not sell your personal information. You have the right to opt out of any future sale of your Personal Information by filling out the form available here: Do Not Sell My Personal Information. (This links to the CCPA notice with fields for a visitor to enter – see other doc.)

For Questions or Concerns:

If you have questions or concerns regarding this Privacy Policy, you should first e-mail us at marketing@gillettepepsi.com.

Changes to the Privacy Policy:

This Privacy Policy is incorporated into our Terms of Use.  We reserve the right to change this Privacy Policy from time to time, consistent with applicable law.  If we do make material changes to this Privacy Policy, the revised Privacy Policy will be posted on our Sites, and we will post a notification of such changes on our Sites.  Such changes, whether in the form of modifications, additions, or deletions, shall be effective when specified in the relevant notification or, if the change is immaterial, immediately upon appearing on our Sites.  Any use by you of our Sites after such changes shall conclusively be deemed to be your acceptance of such revisions.  We encourage you to review this Privacy Policy periodically to be informed of any such revisions.

To the extent there is a conflict between this Privacy Policy and our Terms of Use, the Terms of Use shall supersede and control.

NOTICE TO CHILDREN UNDER THE AGE OF 18 AND THEIR PARENTS OR LEGAL GUARDIANS:

OUR WEBSITES ARE INTENDED FOR ADULTS. WE DO NOT KNOWINGLY OR INTENTIONALLY COLLECT PERSONAL INFORMATION FROM ANYONE UNDER THE AGE OF 18. IF YOU ARE UNDER THE AGE OF 18, PLEASE DO NOT PROVIDE ANY PERSONAL INFORMATION TO US. IF YOU KNOW OF ANYONE UNDER THE AGE OF 18 WHO HAS PROVIDED US WITH INFORMATION, PLEASE CONTACT US IMMEDIATELY AND WE WILL REMOVE THE INFORMATION.  BY USING OUR WEBSITES, YOU REPRESENT THAT YOU ARE AT LEAST 18 YEARS OF AGE.

 

Appendix A

 

To learn more about the categories of Personal Information we collect, how we collect it, the purpose of the collection, and with whom we share the information, please see the list below.

A. Identifiers

Examples: Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or other similar identifiers.
When it is collected: Collected online or offline when you directly provide it to us, through your use of our websites or services, purchasing our products, or from third parties.
Purpose of the collection: We collect this information for the purposes listed in the Use Of Your Information section above.
Who it is shared with: Shared with our affiliates, partners, vendors, and service providers.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Examples: Name, signature, address, telephone number, credit card number, debit card number, or any other financial information. (Some personal information included in this category may overlap with other categories.)
When it is collected: Collected online or offline when you directly provide it to us, through your use of our websites or services, purchasing our products, or from third parties.
Purpose of the collection: We collect this information for the purposes listed in the Use Of Your Information section above.
Who it is shared with: Shared with our affiliates, partners, vendors, and service providers.

C. Protected classification characteristics under California or federal law

Examples: Age (40 years or older), physical or mental disability, sex (including gender, gender identity, gender expression), sexual orientation, veteran or military status.
When it is collected: Collected online or offline when you directly provide it to us, through your use of our websites or services, purchasing our products, or from third parties.
Purpose of the collection: We collect this information for the purposes listed in the Use Of Your Information section above.
Who it is shared with: Shared with our affiliates, partners, vendors, and service providers.

D. Commercial information

Examples: Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
When it is collected: Collected online or offline when you directly provide it to us, through your use of our websites or services, purchasing our products, or from third parties.
Purpose of the collection: We collect this information for the purposes listed in the Use Of Your Information section above.
Who it is shared with: Shared with our affiliates, partners, vendors, and service providers.

E. Biometric information

Examples: Genetic, physiological, behavioral, and biological characteristics
When it is collected: Not collected
Purpose of the collection: N/A
Who it is shared with: N/A

F. Internet or other similar network activity

Examples: Information on a customer’s interaction with a website, application, or advertisement.
When it is collected: Collected online or offline when you directly provide it to us, through your use of our websites or services, purchasing our products, or from third parties.
Purpose of the collection: We collect this information for the purposes listed in the Use Of Your Information section above.
Who it is shared with: Shared with our affiliates, partners, vendors, and service providers.

G. Geolocation data

Examples: Physical location or movements.
When it is collected: Not collected
Purpose of the collection: N/A
Who it is shared with: N/A

H. Sensory data

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
When it is collected: Not Collected
Purpose of the collection: N/A
Who it is shared with: N/A

I. Professional or employment-related information

Examples: Current or past job history
When it is collected: Collected online or offline when you directly provide it to us, through your use of our websites or services, purchasing our products, or from third parties.
Purpose of the collection: We collect this information for the purposes listed in the Use Of Your Information section above.
Who it is shared with: Shared with our affiliates, partners, vendors, and service providers.

 

J. Non-public education information

Examples: Education records directly related to a student maintained by an educational institution.
When it is collected: Collected online or offline when you directly provide it to us, through your use of our websites or services, purchasing our products, or from third parties.
Purpose of the collection: We collect this information for the purposes listed in the Use Of Your Information section above.
Who it is shared with: Shared with our affiliates, partners, vendors, and service providers.

 

K. Inferences drawn from other personal information

Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
When it is collected: Not collected
Purpose of the collection: N/A
Who it is shared with: N/A