Your privacy is important to us. It is Project West's policy to respect your privacy regarding any information we may collect from you across our website, www.projectwest.com, and any other sites we own and operate. WE Soda Ltd is the controller and responsible for your personal data (“we” or “our” in this privacy policy).
This privacy policy will inform you as to how we look after your personal data when you visit our website and tell you about your privacy rights and how the law protects you.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data: this may include first name, maiden name, last name, username or similar identifier,
Contact Data: this may include billing address, delivery address, email address and telephone numbers.
Technical Data: this may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Usage Data: this may include information about how you use our website, products and services.
Marketing and Communications Data: this may include your preferences in receiving marketing from us and our third parties and your communication preferences.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We only ask for personal information when that information is necessary to provide a service to you. We collect it by fair and lawful means, with your knowledge and consent.
We also let you know why we’re collecting it and how it will be used.
We do not actively collect personally identifying data from this website except when specifically and knowingly provided by you.
We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
We may use Email Marketing Service Providers to manage and send emails to you.
We only retain collected information for as long as necessary to provide you with your requested service. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you or as otherwise necessary to comply with [company]’s legal obligations and applicable laws.
What data we store, we’ll protect within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We don’t share any personally identifying information publicly or with third parties, except as and when required to by law.
Our website may link to external sites that are not owned or operated by us. Please be aware that we have no control over the contents and practices of these sites, and cannot accept responsibility or liability for their respective privacy policies.
We do not transfer your personal data outside the US.
This means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Your consent to this privacy policy followed by your submission of such information represents your agreement to that transfer.
We do not knowingly collect personal information from minors under the age of 16 through our website, although certain third-party websites that we link to may do so. These third-party websites have their own terms of use and privacy policies and we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children to never provide information on other websites without their permission.
If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient detail to enable us to delete that information.
This privacy notice section for California residents supplements the information contained in our privacy policy and it applies solely to all visitors, users, and others who reside in the State of California.
Categories of Personal Information Collected
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.
Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by [company], but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us.
Category A: Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.
Collected: Yes.
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
Collected: Yes.
Category C: Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: No.
Category D: Commercial information.
Examples: Records and history of products or services purchased or considered.
Collected: No.
Category E: Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: No.
Category F: Internet or other similar network activity.
Examples: Interaction with our website or advertisement.
Collected:
Category G: Geolocation data.
Examples: Approximate physical location.
Collected: No.
Category H: Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: No.
Category I: Professional or employment-related information.
Examples: Current or past job history or performance evaluations.
Collected: No.
Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: No.
Category K: Inferences drawn from other personal information.
Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: No.
Under CCPA, personal information does not include:
Publicly available information from government records
De-identified or aggregated consumer information
Information excluded from the CCPA’s scope, such as:
Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994
Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
Directly from You. For example, from the forms you complete on our website or preferences you express or provide through our website.
Indirectly from You. For example, from observing your activity on our website.
Automatically from You. For example, through cookies we or our Service Providers set on your Device as you navigate through our website.
From Service Providers. For example, third-party vendors to monitor and analyze the use of our website, third-party vendors to provide advertising on our website, or other third-party vendors that we use to provide the website to you.
Use of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose personal information we collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:
To operate our website and provide you with our website.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our website.
To fulfil or meet the reason you provided the information. For example, if you share your contact information to ask a question about our website or TC Soda Holdings Inc., we will use that personal information to respond to your inquiry.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA.
For internal administrative and auditing purposes.
To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.
Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section.
If we decide to collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes we will update this privacy policy.
Disclosure of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:
Category A: Identifiers
Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Category D: Commercial information
Category F: Internet or other similar network activity
Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.
When we disclose personal information for a business purpose or a commercial purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
Share of Personal Information
We may share your personal information identified in the above categories with the following categories of third parties:
Service Providers
Our affiliates
Our business partners
Third party vendors to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you
Your Rights under the CCPA
The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:
The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
The right to request. Under CCPA, you have the right to request that we disclose information to you about our collection, use, sale, disclosure for business purposes and share of personal information. Once we receive and confirm your request, we will disclose to you:
The categories of personal information we collected about you
The categories of sources for the personal information we collected about you
Our business or commercial purpose for collecting or selling that personal information
The categories of third parties with whom we share that personal information
The specific pieces of personal information we collected about you
If we sold your personal information or disclosed your personal information for a business purpose, we will disclose to you:
The categories of personal information categories sold
The categories of personal information categories disclosed
The right to say no to the sale of Personal Data (opt-out). You have the right to direct us to not sell your personal information. To submit an opt-out request please contact us.
The right to delete Personal Data. You have the right to request the deletion of your Personal Data, subject to certain exceptions. Once we receive and confirm your request, we will delete (and direct our Service Providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:
Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your consumer’s rights, including by:
Denying goods or services to you
Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
Providing a different level or quality of goods or services to you
Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services
Your continued use of our website will be regarded as acceptance of our practices around privacy and personal information.
TC Soda Holdings Inc. may revise this privacy policy for its website at any time without notice. By using this website, you acknowledge and agree to be bound by the then current version of this privacy policy. These terms of use were last updated on 20 January 2023. TC Soda Holdings Inc. is not responsible for but will endeavor to provide notice to you of revision of this privacy policy.
If you have any questions about this privacy policy or our privacy practices, please contact Ed Westropp at [email protected].
For further information, see our Terms of Use and Cookie Policy.
You have the right to make a complaint with the appropriate data protection authority if you have concerns about how we process your personal data. We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority, so please contact us in the first instance.
This policy is effective as of February 2023.