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PRIVACY POLICY

This privacy policy applies between you, the User of this Website, and Innovinity Ltd, the owner and provider of this Website. Innovinity Ltd takes the privacy of your information very seriously. This policy applies to our use of any and all personal data collected by us or provided by you in relation to your use of the Website and our services, including promotional activities such as Share a Coke and purchases processed through partners such as Coca‑Cola and Payment Processing Partners.

Please read this privacy policy carefully.

DEFINITIONS AND INTERPRETATION

In this privacy policy, the following definitions are used:

  • Data: Collectively all personal information that you submit to Innovinity Ltd via the Website, email, order forms, campaign platforms (e.g. Coca‑Cola), or by any other means.
  • Cookies: A small text file placed on your device by this Website when you visit or use certain features of the Website.
  • Data Protection Laws: Any applicable law relating to the processing of personal data, including but not limited to the UK GDPR, the Data Protection Act 2018, and PECR.
  • GDPR: The General Data Protection Regulation (EU) 2016/679.
  • Innovinity Ltd, “we” or “us”: A company incorporated in England and Wales with registered number 12856774 and registered office at 69 Gazelle Road, Weston-Super-Mare, Somerset, BS24 9ES.
  • We are registered with the Information Commissioner’s Office (registration number:  ZB249004. As the controller, we are responsible for looking after your personal data.
  • User or “you”: Any third party that accesses the Website and is not employed by Innovinity Ltd.
  • Website: The website you are using, including https://innovinity.com and any associated subdomains, such as those for Share a Coke campaigns and promotional microsites.

SCOPE OF THIS PRIVACY POLICY

  • This policy applies only to the actions of Innovinity Ltd and users with respect to this Website and related promotional services and platforms, including Share a Coke and other branded campaigns where Innovinity Ltd acts as a controller or processor.

    https://www.coca-cola.com/gb/en/offerings/share-a-coke/customisation
    https://www.coca-cola.com/gb/en/offerings/share-a-coke/customisation/customisation

We are committed to protecting and respecting your privacy. This privacy notice sets out how we collect and use your personal data, outlines your rights, and explains what to do if you have any questions or concerns.

DATA WE MAY COLLECT

We may collect and process the following types of personal data:

What personal data do we collect?
When we refer to personal data, we mean any information that relates to you that may (either on its own or in combination with other information) identify you. We may collect the following types of personal data:

  • Identity and contact information: This may be your information and it may also be the information of the recipient where this is not you. This information may include title, name, date of birth, contact details (such as email address, physical address, and telephone number), other information about who you are and personalised messages submitted by you.
  • Technical data: Some information is automatically collected by our website, and includes your internet protocol (IP) address, information about your internet browser, and other technical information about the devices you use to access our websites. Collecting this information allows us to ensure that content is presented in the most effective manner for you and for your computer, and that our site is safe and secure.
  • Website usage data: We may collect information about the way that you use our websites through cookies if you agree to use of cookies.
  • Financial information: Such as bank account details and credit card information.
    • Full name
    • Date of birth (where required)
    • Email address
    • Postal and/or delivery address
    • Contact number
    • IP address and device information (automatically collected)
    • Campaign interaction data (e.g., personalised messages submitted)
    • Moderation history and approval status
    • Fulfilment and transaction records
    • Preferences and participation choices

HOW WE COLLECT YOUR DATA

Your data is collected:

  • When you submit forms or place orders via our Website or campaign microsites.
  • When you register or authenticate using Coca‑Cola accounts.
  • Through cookies and similar technologies on our platforms.
  • When you contact us by phone, email, or post.
  • When data is transferred to us from trusted partners (e.g., Coca‑Cola or Payment Processing Partners) for the purpose of order / payment processing and fulfilment.
  • Direct interactions: We collect personal data that you provide to us, this includes information you provide when you buy a personalised coke can as part of Share a Coke, communicate with us through our website contact forms or via email, and through our interactions with you.
  • Automated interactions: As you interact with our websites, technical data is automatically collected (see below for further information).
  • Third parties: We may also receive personal data from third parties. This may include:
    • Technical data about your use of our websites from analytics providers such as Google.
    • We may receive personal data about you through third-party referrals, for example by clicking through to our website from a third party website.

LAWFUL BASES FOR PROCESSING

We process your personal data on the following lawful bases:

  • Contract: To fulfil your order or participate in a promotion
  • Consent: When you explicitly agree to receive marketing or share data with Coca‑Cola or Payment Processing Partners
  • Legal obligation: To comply with tax, customs, or regulatory requirements
  • Legitimate interest: To improve services, protect legal rights, and operate secure systems

PURPOSES FOR USING YOUR DATA

We use your data for the following purposes:

  • To enable personalisation of products
  • To fulfil and deliver your order
  • To process payments via Payment Processing Partners
  • To perform moderation checks against content guidelines
  • To contact you regarding your order or enquiry
  • To facilitate campaign-specific experiences in collaboration with Coca‑Cola
  • To generate anonymised analytics and performance reports

DATA SHARING WITH THIRD PARTIES

We may share your data with:

  • Coca‑Cola (as campaign lead and brand controller)
  • Payment Processing Partners (as ecommerce platform and payment processor)
  • Fulfilment partners, couriers, and logistics providers
  • Our IT providers and platform hosts who support our digital infrastructure
  • Regulators or authorities when required by law

We never sell or rent your personal information to third parties.

PAYMENT PRIVACY COMPLIANCE

When making a purchase, you may be redirected to our partners platform. Payment partners acts as the merchant of record for your transaction. Their privacy practices are governed by their own Privacy Policy, which you can access here. We encourage you to read their policy carefully, as they are responsible for data collection and processing related to your transaction and payment. 

INTERNATIONAL DATA TRANSFERS

If personal data is transferred outside the UK or EEA:

  • It is only transferred to countries that provide an adequate level of protection, or
  • It is protected using appropriate safeguards such as Standard Contractual Clauses or equivalent agreements

COOKIES AND TRACKING TECHNOLOGIES

Our Website uses cookies to:

  • Store your preferences
  • Analyse site usage and performance
  • Enable secure login and campaign functionality

You can manage cookie preferences through your browser. See our Cookie Policy for full details.

DATA SECURITY

We take data security seriously and implement technical and organisational measures such as:

  • HTTPS encryption and SSL certificates
  • Access controls and authentication measures
  • Regular system audits and monitoring

DATA RETENTION

We retain personal data:

  • For the duration required to fulfil your order or campaign entry.
  • For up to 12 months post-campaign for compliance and audit.
  • Longer if legally required (e.g. tax or regulatory requirements).

YOUR RIGHTS UNDER GDPR

You have the right to:

  • Access the personal data we hold about you. You can request a copy of the personal data we hold about you.
  • Request rectification of inaccurate or incomplete data You can ask us to correct any personal data we hold about you if it is inaccurate or incomplete.
  • Request erasure (“right to be forgotten”) You have the right to ask us to delete your personal data, for example if we no longer need it for the purpose we collected it for.
  • Object to or restrict processing You can object to us processing your personal data if we are relying on ‘legitimate interests’ as our legal basis. You also have the right to object to your data being used for direct marketing
  • Data portability (where applicable) You can ask us to transfer your personal data to you or to a third party.
  • Lodge a complaint with the ICO (www.ico.org.uk)

These rights do not apply in all circumstances, and we may be able to refuse or partially refuse requests in certain circumstances such as where a legal exemption applies. In most cases we have one month to respond to you. Sometimes, we may need to verify your identity before we are able to process a request.To exercise these rights, email us at: privacy@innovinity.com

CHILDREN’S PRIVACY

We do not knowingly collect or process data from children under 13. If we learn that we have collected such data inadvertently, we will delete it promptly.

MARKETING COMMUNICATIONS

We may contact you for marketing purposes if you have given us clear and specific consent to do so. You can opt out at any time by clicking ‘unsubscribe’ in any email or contacting us directly.

Automated decision-making and profiling
We do not use personal data for automated decision-making (including profiling). If this changes, we will update this privacy notice and let you know (where appropriate).

Complaints
If you would like to raise a complaint, please contact us and we will aim to resolve it. If you are not satisfied, you have the right to make a complaint to the Information Commissioner’s Office (ICO). Details on how to do this can be found at https://ico.org.uk/make-a-complaint/.

CHANGES TO THIS PRIVACY POLICY

This privacy notice was published on 15.05.2025.  We may update this privacy policy from time to time. The most recent version will always be available on our Website.

Version 2.2 – April 2025

 

For the purposes of data protection law, the controller of your personal data is Innovinity Ltd. We are registered with the Information Commissioner’s Office (registration number:  ZB249004. As the controller, we are responsible for looking after your personal data. Our contact details are as follows:

CONTACT US

Data Protection Officer

Innovinity Ltd
69 Gazelle Road
Weston-Super-Mare
BS24 9ES
Email: privacy@innovinity.com

COOKIE POLICY

    1.    What Are Cookies?
Cookies are small text files that are stored on your device (computer, smartphone, tablet) when you visit a website. They help the website recognise your device and remember information about your visit, such as your preferences, login status, and usage patterns.

 

    2.    Types of Cookies We Use
We use the following categories of cookies on our Website:

a. Strictly Necessary Cookies
These cookies are essential to enable you to use our site securely and perform basic functions such as logging in, navigating the website, and submitting forms. Without these cookies, services like personalisation or order processing cannot function.

b. Performance and Analytics Cookies
These cookies help us understand how visitors interact with the Website by collecting anonymous information, such as page visits, traffic sources, and error messages. We use tools such as Google Analytics for these purposes.

c. Functionality Cookies
These cookies allow the Website to remember your choices (e.g. your language or region) and provide enhanced, more personalised features.

 

    3.    Cookies Used by Third Parties
Some cookies are set by third-party services that appear on our Website. These may include:

  • Payment Processing Partners: For managing international ecommerce transactions and payment preferences.
  • Coca‑Cola (and associated platforms): For managing campaign activity, moderation preferences, and platform login.
  • Delivery or logistics partners (e.g. DHL): To track parcels and support fulfilment processes.

These third parties have their own privacy and cookie policies. We encourage you to review them:

  • Payment Processing Partners Cookie Policy
  • Coca‑Cola Privacy Policy

 

    4.    Managing Your Cookie Preferences
You can control and manage your cookie preferences in the following ways:

  • Browser Settings: You can delete or block cookies through your browser settings. Most browsers also allow you to disable cookies altogether.
  • Consent Banners: On your first visit to our Website, you will be asked whether you wish to accept or manage cookies. You can change these preferences at any time.

Please note: Disabling some cookies may impact the functionality and performance of the Website.

 

    5.    How Long Cookies Are Stored
Cookies are either:

  • Session Cookies: Temporary cookies that are deleted when you close your browser.
  • Persistent Cookies: These remain on your device until they expire or are deleted manually.

Our cookies typically remain active for up to 12 months, depending on their function.

 

    6.    Updates to This Cookie Policy
We may update this Cookie Policy from time to time to reflect changes to legislation or our data practices. The latest version will always be published on our Website.

Last Updated: April 2025

 

Contact Us

If you have any questions about our use of cookies, please contact:

Email: privacy@innovinity.com
Data Controller: Innovinity Ltd, 69 Gazelle Road, Weston-Super-Mare, BS24 9ES