Privacy Policy

My Cola and data privacy

My Cola Beverages (Pvt) Ltd and its subsidiaries ("My Cola") are committed to protecting and respecting your privacy.

This privacy policy sets out the basis on which we will process any personal information that we may collect about you as a visitor to our website or premises or a contact at one of our customers or potential customers, suppliers or potential suppliers or other business partners or in any other cases where we specifically state that this policy will apply.

This privacy policy also sets out how we protect your privacy and your rights in respect of our use of your personal information.

My Cola may have a privacy policy or statement specific to particular local laws, products, or services in which case such policy or statement shall supersede or supplement this privacy policy.

What personal information do we collect from you?

We may collect and process the following personal information about you:

Personal information that you give us: This is information about you that you give to us by filling in forms on our website (or other forms that we ask you to complete), giving us a business card (or similar), or corresponding with us by telephone, post, email or otherwise. It may include, for example, your name, address, email address, and telephone number; information about your business relationship with MY COLA; and information about your professional role, background, and interests.

Personal information that our website and other systems collect about you:

Other information: We may also collect some information from other sources. For example:

How will we use your personal information?

We may collect, store and use your personal information for the following purposes: to operate, manage, develop and promote our business (including our products and services) and, in particular, our relationship with the organization you represent (if any) and related transactions including, for example:

to protect our business from fraud, money-laundering, breach of confidence, theft of proprietary materials, and other financial or business crimes; to comply with our legal and regulatory obligations and bring and defend legal claims and assert legal rights; and if the purpose is directly connected with an assigned purpose previously made known to you.

We may from time to time review your information held in our systems – including the contents of and other information related to your email and other communications with us – for compliance and business protection purposes as described above. This may include reviews for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations. To the extent permitted by applicable law, these reviews will be conducted in a reasonable and proportionate way and approved at an appropriate level of management. They may ultimately involve the disclosure of your information to governmental agencies and litigation counterparties as described below. Your emails and other communications may also occasionally be accessed by persons other than the member of staff with whom they are exchanged for ordinary business management purposes (for example, where necessary when a staff member is out of the office or has left MY COLA). We will only process your personal information as necessary so that we can pursue the purposes described above and where we have a legal basis for such processing. Where our lawful basis for processing is that such processing is necessary to pursue our legitimate interests, we will only process your personal information where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest. In exceptional circumstances, we may also be required by law to disclose or otherwise process your personal information.

How long do we keep your personal information?

We will delete your personal information when we no longer need such personal information, for instance, where: i. it is no longer necessary for us to retain your personal information to fulfill the purposes for which we had collected it; ii. we believe that the personal information that we hold is inaccurate; or iii. in certain cases where you have informed us that you no longer consent to our processing of your personal information. Sometimes, however: a. there are legal or regulatory requirements which may require us to retain your personal information for a specified period, and in such cases, we will retain your personal information for such specified period; and b. we may need to retain your personal information for certain longer periods for product liability purposes or in relation to legal disputes, and in such cases, we will retain it for much longer periods to the extent required. Note that we may retain some limited information about you even when we know that you have left the organization that you represent, so that we can maintain a continuous relationship with you if and when we are in contact with you again, representing a different organization.

What are your rights?

You have the following rights (subject to applicable local laws) in relation to the personal information that we hold about you:

- to access your personal information, and some related information, under relevant data protection law;
- to require any inaccurate personal information to be corrected or deleted;
- to object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances;
- to require us to delete your personal information in certain circumstances;
- to require us to restrict or block the processing of your personal information in certain circumstances (when processing is restricted, we can still store your personal information, but may not use it further);
- to obtain from us your personal information, in a structured, commonly used and machine-readable format in certain circumstances. Further, you may have the right to require us to transmit your personal information directly to another person (for instance a new provider) where it is technically feasible to do so; and where we are processing your personal information based on your consent to such processing, to withdraw your consent at any time.

Further information and advice about your rights can be obtained from the data protection regulator in your country.

Sensitive Information

We request you not send to us or share with us any sensitive personal information (e.g. information related to racial or ethnic origin, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background, or trade union membership).

Personal Information of Children

MY COLA respects the privacy of children and does not knowingly collect, use or disclose personal information of children under 16 years of age without verifiable consent from a parent or guardian.

If MY COLA becomes aware that the information submitted to or collected by MY COLA is personal information of children without first receiving verifiable consent from a parent or guardian, MY COLA will take prompt steps to delete such personal information.

Automated Decision Making

We may use technology that tracks your use of our website and your interactions with us and which helps us to build a profile of your preferred products and information requests. If we do this, what this means for you is that you are more likely to receive offers and information that are tailored to your specific preferences, based on your previous profile activity.

If we use automated decision making in respect of any specific service or product and such automated decision making produces legal effects concerning data subjects or similarly significantly affects them, we will provide the information required by applicable laws in respect of such automated decision making.

Changes to this policy

This privacy policy is valid from the time of its publication on the MY COLA website, and all previous versions of this privacy policy become invalid as of such time. Any changes we make to this privacy statement in the future will be posted to our website and also available if you contact us. Please check back frequently to see any changes.