Privacy

Privacy Policy – PepsiCo

1 - Who is covered by this policy?

PepsiCo, Inc., together with all its related bodies corporate in Australia (including but not limited to PepsiCo Australia Holdings Pty Ltd ABN 25 079 719 743, The Smith’s Snackfood Company Pty Ltd ABN 31 057 976 940, Sakata Rice Snacks Australia Pty Ltd ABN 94 064 157 026 and Quaker Oats Australia Pty Ltd ABN 73 065 540 865) (collectively “PepsiCo Group”, “we”, “us” or “our”) respects and is committed to protecting your privacy.

This document is our Privacy Policy and describes how we will comply with our obligations under the Privacy Act 1988 (Cth) (“Privacy Act”) in relation to the handling of your personal information. If you do not agree to anything in this policy, you should not supply us with any personal information, however this may impact or restrict our ability to interact with you.

2 - What is covered by this policy?

This policy sets out how we manage your “personal information”. When used in this policy, the term “personal information” has the meaning given to it in the Privacy Act, including as amended from time to time. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address, postcode, date of birth, device/IP information, certain engagement preferences, product/offer preferences, profession or occupation and the content of your interactions with us, our service providers or the third parties that we engage. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

3 - Collection

We collect personal information in the course of our business dealings with you and third parties. Generally, and as appropriate, we will tell you why we are collecting personal information, when we collect it and how we plan to use it, or these things will be obvious when we collect the information. We usually collect personal information such as name, email and street address, telephone number, and records of your communications and interactions with us.

If you do not provide us with the personal information described below, some or all of the following may happen:

  • we may not be able to provide any products, services or offers to you, either to the same standard or at all;
  • we may not accept a request by you to participate in a promotion on the basis that it is not complete and does not meet our requirements;
  • we may not be able to respond to enquiries or investigate a complaint received from you;
  • we may not be able to provide you with information about products or services that you may want, including information about special promotions;
  • we may be unable to tailor the content of our websites and apps to your preferences and your experience of our websites and apps may not be as enjoyable or useful; or
  • we may not be able to consider your application for employment or an application to provide contracted services.

As a general rule we do not solicit sensitive information (as defined in the Privacy Act). However, profile images may be provided to us if you use a third-party website to sign up to the SnackBack App. We will only use or disclose any sensitive information we collect about you with your consent or where we are otherwise permitted by law to do so. We will also take reasonable steps to provide you with notice of the purposes for any such use or disclosure.

The below are examples for when we may collect personal information:

When you engage with us

We may collect your personal information through our websites, the SnackBack App (including from third parties where you use a third-party account, such as Facebook, Apple or Google to sign in), by phone, email, or through your participation in a promotion, competition, or survey (including any documentation or information you share with us as part of your participation). Such promotions, competitions or surveys may be conducted through third party websites (including PepsiCo Group branded sites which may be managed by third parties) or through social media platforms such as Facebook, Snapchat, Instagram, LinkedIn and TikTok.

You should only engage with us via third party websites, social media platforms, or sign up to the SnackBack App via a third-party account (eg Apple, Google or Facebook) if you are happy for them to share your public profile (which may include a picture of you) with us. If you don’t consent to that, then please engage with us directly (for example by signing up to the SnackBack App directly with us).

When you are a prospective employee

We may also collect your personal information during the recruitment process when you enquire about or apply for any positions at PepsiCo Group. It may be collected as part of your application submitted or provided to us by a third party such as a recruitment agency. We may also collect your personal information if you or your employer propose to provide contracted services to us. In these circumstances your personal information may be provided by you directly to PepsiCo Group or by your employer providing us with your personal details. Any personal information submitted to PepsiCo Group, and the use and protection of such information is governed by the Australian Privacy Principles within the Privacy Act. Further information on the Australian Privacy Principles can be found on the Office of the Australian Information Commissioner’s website.

When we deal with third parties

There may be occasions when we collect information about you from someone else. We may collect personal information about you in the course of our business dealings with third parties, such as social media platforms and information service providers. We may contract with these third parties (including use of analytics and targeted advertising technology) to supplement our records (including identifying your preferences, shopping behaviours and other characteristics (such as demographics, socio-economic and socio-cultural behaviours) that may affect your shopping decisions), improve our websites, apps, products, marketing and personalisation of our services to you and our consumers. Your interactions with these third parties are governed by the privacy policies of the companies providing them. If you are logged in to your social media account, it is possible that the respective social media network can link your social media profile with your online interactions with us and other products and services. When we work with third parties, we require them to restrict their data processing to only what is necessary to provide us with the services that we request.

If you provide us with personal information about another person, you represent that you have told that person about this policy and have their consent to provide information to us. We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users browse our websites. We may also collect de-identified or hashed usage data from third parties or service providers for the purpose of targeting advertising, analysis, and improvements to our websites and/or products.

When you are an employee

From time to time we may ask our employees to provide personal information to us, including sensitive information such as health information and biometric information, or seek their consent to the collection of their personal information from a third party. Some of this information may be subject to the exemption in relation to employee records in the Privacy Act but, to the extent that it is not, it will be dealt with in accordance with all applicable laws, our relevant employment policies and this privacy policy.

4 - Use and Disclosure

We primarily use and disclose your information to provide and market our products to you and to fulfil administrative functions associated with our business activities.

The below are examples for when we may also use and disclose your personal information:

  • Responding to you: to answer, process and respond to your complaints or enquiries, including by and providing information or advice about existing and new products and services;
  • Research and insights: to conduct product and market research, and to understand your preferences, patterns, interests and behaviours that may affect your shopping decisions (including by supplementing our records with data from third parties). We may generate reporting, insights and analysis based on this data;
  • Website access: to provide you with access to protected areas of our websites;
  • Review performance of our digital platforms: to assess the performance and improve the operation of our websites and digital platforms (including the SnackBack App);
  • Fulfilling operational and technical functions: to process payments, deliver orders, manage promotions, provide you with offers, provide refunds and discounts, verify your identity, and provide personal information to our related bodies corporate, contractors, service providers or other third parties;
  • Administration, personalisation, marketing and operation of the SnackBack App: in respect of the SnackBack App, to administer your account (including verification of your age and identity), ensure a more personalised and tailored app experience, enable you to redeem offers and rewards or enter promotions, tailor and target advertising to you based on your preferences, to contact you about our offers, rewards, promotions and product news, and to avoid the need for you to enter the same information multiple times;
  • Product development: for the administrative, planning, product or service development, quality control and research purposes of us and our related bodies corporate, contractors or service providers;
  • Updating our records: to update our records and keep your contact details up to date, including by providing your updated personal information to our related bodies corporate, contractors or service providers;
  • Legally required or authorised: to comply with any legal obligation (including laws, rules, regulations, lawful and binding determination, decision or direction of a regulator, court or tribunal or in co-operation with any governmental authority) or as otherwise as required or authorised under an Australian law;
  • Business restructuring: to protect our lawful interests and facilitate purchases and potential purchases of our businesses;
  • When you provide us with your consent;
  • Marketing and advertising: for the purposes of showing consumers relevant advertising from us and our related bodies corporate, contractors or services providers, including:
    • when we provide marketing communications and targeted advertising to you on an ongoing basis by telephone, electronic messages (e.g. email and SMS) and other means, including via the SnackBack App. You can unsubscribe from marketing communications at any time via the “unsubscribe” link in an electronic marketing communication, via your Notification Settings in the SnackBack App in relation to SnackBack marketing communications, by calling us on 1800 500 502, or you can contact us using the other contact details below;
    • when we share certain information with third parties and social media platforms, to identify and create audiences with similar interests. We may then tailor our advertising to be more relevant for these audiences.

We may also disclose your information to:

  • service providers, contractors and strategic partners from time to time to help us provide and market our products to you;
  • our employees, related bodies corporate, contractors or service providers for the purposes of operation of our websites and apps or our business, fulfilling requests by you, and to otherwise provide services to you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants;
  • suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes;
  • our business partners, who will use your information to tell you about products or services which we think may be of interest to you; and
  • any organisation for any authorised purpose with your consent.

Some of these companies may be located overseas, including in the US, UK and Belgium. Such information will be shared on a confidential basis, and our agencies and partners will only be permitted to use it to provide services to us, or as otherwise required by law. If we do this, we will also take steps to ensure those parties protect your information in the same way we do. From time to time, we may share your information with our business partners who will use your information to tell you about products or services which we think may be of interest to you – if we propose to do this, we will get your consent before doing so.

We may also combine any information that we collect from you with information collected by any of our related bodies corporate and may share information that we collect with them.

5 - Our websites and apps

5.1 - Application of this policy

This policy also applies to the SnackBack App and our websites that display or link to it including www.pepsico.com.au, www.pepsimax.com.au, www.gatorade.com.au, www.smiths.com.au, www.doritos.com.au, www.redrockdeli.com.au, www.bublywater.com.au, www.popcorners.com.au, www.sunbites.com.au, and www.smiths-chips.com.au

5.2 - Cookies and other similar technologies

When you access our websites, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer. This enables us to recognise your computer and greet you each time you visit our websites without bothering you with a request to register. It also enables us to keep track of goods and services you view so that, if you consent, we can send you news about those goods and/or services. We also use cookies to measure traffic patterns, to determine which areas of our websites have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our products and services. If you do not wish to receive cookies, you can set your browser so that your web browser does not accept them. We may log IP addresses (that is, the electronic address of a device connected to the internet) to analyse trends, administer our websites, track users’ movements, and gather broad demographic information.

When you use the SnackBack App or access our websites, we may also use other similar technologies, including your Apple IDFA, GAID and IP address and software such as AppsFlyer and Google Firebase, to collect information about use of the SnackBack App and our websites. We may use and disclosure this information to analyse demographic trends, improve our products and marketing, and as outlined in section 4. Where we have received your Apple IDFA, GAID or IP address, this may also be shared with third parties (like Facebook, Google, SnapChat, TikTok or other advertising platforms) for the purposes of targeting advertising tailored to your preferences. Whether or not we receive your Apple IDFA or GAID will depend on your Apple or Google account settings.

5.3 - Security

As our websites and apps are linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

5.4 - Links

Our websites may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.

6 - Direct marketing materials

We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. If you sign up to the SnackBack App, you may receive email communications and push notifications about any of the many food and beverage products in our portfolio, which you can find out more about here (https://www.pepsico.com/our-brands/creating-smiles/our-products).

You may opt-out of receiving marketing communications from us at any time by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications or the SnackBack App and we will then ensure that your name is removed from our marketing list. If you have the SnackBack App, and wish to opt out of push notifications, you may do so via your Notification Settings in the App. As set out in and in accordance with section 4 above, we may provide your personal information to other organisations, for example our marketing agencies, for the purposes of them providing services to us in relation to our direct marketing.

7 - Do we disclose your information to anyone outside Australia?

We may disclose personal information to our related bodies corporate and our third-party suppliers and service providers located overseas for some of the purposes listed above and in accordance with the terms set out in section 4 above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your information.

Some of our subsidiaries, related companies and/or programs may have their own, possibly different, policies that are posted on their own websites. If you visit their websites or otherwise deal with any of them directly, we encourage you to review those policies.

The entities located outside of Australia to whom we may disclose your personal information include the following:

  • our related bodies corporate, located in the United States of America, the UK and New Zealand;
  • our data hosting and other IT service providers, located in the United States of America, the UK, Belgium, Singapore and India;
  • our accounts receivable and claims processing providers, located in India; and other third parties located in the United States of America and New Zealand.
8 - Security and data quality

We hold personal information electronically and in hard copy form, both at our premises and with the assistance of our service providers. We use a variety of physical and electronic security measures including restricting physical access to our offices, firewalls and secure databases to keep personal information secure from misuse interference and loss and from unauthorised access, modification or disclosure.

We take reasonable steps to ensure that the personal information that we collect, use and disclose about you is accurate, complete and up-to-date and, in relation to the purpose of our use or disclosure, relevant. Personal information is destroyed or de-identified when it is no longer needed or where we are no longer required by law to retain it (whichever is the later).

9 - Approach

We are bound by the Australian Privacy Principles in the Privacy Act and will collect, handle, store and disclose your personal information in accordance with our legal obligations under the Privacy Act, including as amended from time to time. To the extent that an exemption applies which means some or all of the requirements of the Privacy Act do not apply to your personal information, we may rely on that exemption when dealing with your personal information.

10 - Access, correction and deletion

You may request access to any personal information that we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a reasonable fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and will not charge for making any corrections to your personal information.

There may be instances where we cannot grant you access to the personal information that we hold about you. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, and if it is reasonable to do so, we will give you written reasons for any refusal.

If you believe that any personal information that we hold about you is incorrect, incomplete or inaccurate, then you may request that we amend it. We will consider if the information requires amendment and notify you of our decision.

For any personal information that we hold about you, we will:

  • respond to your request for the correction of your personal information within a reasonable time (usually within 30 days);
  • if we agree to your request, promptly correct any personal information that we hold about you that we are satisfied is inaccurate, out-of-date, incomplete, irrelevant or misleading; and (to the extent we do not agree that there are grounds for amendment) not correct your personal information. However, you may request that we add a note to the personal information stating that you disagree with it.

You can request to delete your SnackBack account by following the prompts in the Profile settings of the SnackBack App. After you submit this request, your SnackBack account will be suspended pending deletion. Once we delete your SnackBack account, we will delete or de-identify the personal information we have collected from you through the SnackBack App, except for your email address and mobile number which we will retain only in connection with fraud identification and preventing and checking compliance with the SnackBack App Terms of Use. You can view a copy of the SnackBack App Terms of Use on the SnackBack App or by contacting us using the details in section 12 (Contact Us) below

11 - What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it.

If you wish to make a complaint that relates to your personal information, you should first lodge your complaint with us using the details in section 12 (Contact us) below and provide us with details of the incident so that we can investigate it.

We will treat your complaint confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.

If you are not satisfied with our handling of your complaint or our proposed resolution, you have a right to lodge a further complaint with the Office of the Australian Information Commissioner (for more information, please see www.oaic.gov.au). The Office of the Australian Information Commissioner can provide you with further information about the next steps in its complaints process.

12 - Contact us

If you have any questions about this policy, any concerns or a complaint regarding the treatment of your personal information or you want to notify us of a possible breach of your privacy, please contact the PepsiCo Group Privacy Officer as follows:

Phone: 1800 025 789
Email: consumer.cic@pepsico.com
Post:
Tower A, Level 4
799 Pacific Highway
Chatswood, NSW 2067
Australia

13 - Changes to our privacy policy

We may change this privacy policy from time to time. Any updated versions of this policy will be posted on our website and will be effective from the date of posting.

This policy was last updated in March 2024.