Privacy Policy

Privacy Policy

Coke Buddy For Sales

1. Introduction to our Privacy Policy

Welcome to the Coke Buddy For Sales application ("Coke Buddy For Sales", "we", "us", or "our"). This Privacy Policy explains how we collect, process, protect, and retain your Personal Data when you interact with our application.

We process your Personal Data securely, transparently, and strictly based on your Consent or for Certain Legitimate Uses as defined under the law.

2. Whose Data Do We Collect?

We collect data only from Market Growth Representatives (MGR), who visit retailers across various defined geographical territories to understand Customer's order needs and check their coolers' working conditions.

3. Personal Data We Collect (How the App Accesses and Gathers Data)

Depending on your role and the features you access, the Application accesses and gathers the following categories of information:

  1. Account and Identity Information: User ID is the unique territory ID defined for each sales territory of the MGR.
  2. Device Information: Device model, Operating system version, App version, Device identifiers required for authentication and security, Diagnostic and crash information of the MGR.
  3. Location Information: Approximate and precise location information, including location information while the App is running in the foreground or background, when required for authorized business activities such as outlet visits, route compliance verification, attendance and field activity validation, delivery or service verification, and sales execution activities of the customer and MGR.
  4. Camera and Image Data: Where enabled, the App may use the device camera to record merchandising displays, verify field execution activities, and support image-based business processes of the customer.
  5. Log and Usage Information: App usage, feature utilization, login history, error logs, performance metrics, and security events of both the customer and MGR as applicable.
  6. Permissions Accessed: Depending on enabled features, the Application may request access to Location, Camera, Storage/Photos, Internet Access, and Notifications.

4. Purpose of Processing Data (How We Utilize the Data)

We utilize processed Data strictly for the following purposes:

  1. Authenticate users and provide Application services for the MGR.
  2. Process sales and distribution transactions of the customer.
  3. Manage outlet and customer interactions.
  4. Validate field activities and improve operational efficiency.
  5. Support business reporting and analytics.
  6. Ensure application security, detect fraud and misuse, and troubleshoot technical issues.

5. Data Retention and Removal

We adhere to strict data minimization and retention standards. We retain information only for business operational requirements, legal and regulatory requirements, security investigations, audit requirements, and contractual obligations.

For the application usage, the data is retained for a period of 3 (Three) years and thereafter gets auto-deleted. However, we may need to keep transactional data / geo location data for longer than our specified retention periods as mentioned above, to comply with legal or other obligations in the backend systems. In such a scenario, the data is securely deleted, anonymized, or archived in accordance with HCCBPL data retention policies.

6. Personal Data Security and Confidentiality

The security of your Personal Data is important to us. To prevent unauthorized access, disclosure, or improper use of your information, and to maintain data accuracy, we have established physical, technical, and administrative safeguards to protect the Personal Data we collect.

7. Processing of Children's Data

Coke Buddy For Sales application and business operations are intended for adults (18 years and above). We do not intentionally track, collect, or process the Personal Data of children, nor do we engage in targeted advertising aimed at children. If we discover that a child's data has been inadvertently collected, we will erase it immediately.

8. Your Rights as a Data Principal

Under the DPDPA 2023, you are empowered with the following rights regarding your Personal Data:

  1. Right to Access & Information: You can ask us for a summary of your Personal Data being processed, the identities of Data Processors we have shared it with, and the purpose of the processing (subject to certain restrictions). Requests unfounded, excessive or repetitive may not be answered to.
  2. Right to Correction & Erasure: You can request that we update, correct, or complete any inaccurate data, or permanently erase your data when it is no longer needed. Note this is not an absolute right, as we may have legal or legitimate grounds for retaining your personal data.
  3. Right of Grievance Redressal: You have the right to readily available means of resolving grievances regarding your data.
  4. Right to Nominate: You may nominate another individual to exercise your rights on your behalf in the event of your death or incapacity.

You can send a Rights request through the following URL:
https://collector.consent.in/select-profile?ci=LE004.1443d9a4af5741059fdee0568396cebf

9. Data Breaches and Security Incidents

If HCCBPL becomes aware of a systems security breach by an unauthorized party or that any user data was used for an unauthorized purpose, we will comply with relevant data breach laws. We will notify users of any breach resulting in unauthorized release of data electronically, at minimum, and without unreasonable delay so that you can take appropriate steps. The notification will include: date of the breach, the types of information that were subject to the breach, a general description of what occurred, and steps HCCBPL is taking to address the breach.

10. Grievance Redressal & Contact Information

If you have any questions about this Privacy Policy, wish to exercise your rights, or want to raise a grievance, please contact our designated Grievance Officer:

  1. Name: Veena J
  2. Email Address: grievance_dpo@coca-cola.in
  3. Mailing Address: Hindustan Coca-Cola Beverages Pvt. Ltd., Brigade Magnum, B Wing, 7th to 9th Floors, Bellary Road, Kodigehalli Gate, Bangalore- 560092