KDP PRIVACY POLICY

This Privacy Policy applies to the Services to which it is linked. If a particular Service has its own privacy policy, then that policy – not this Privacy Policy – applies. This Privacy Policy does not apply to information that is collected by any third-party websites or services that you may access through the Services.

There are several ways we may obtain information about you, including through (A) information you provide to us directly; (B) information that we automatically collect; and (C) information we receive from third parties. Some of the information directly or indirectly identifies you as an individual. When information identifies or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, we refer to it as “Personal Information.” This Personal Information includes the following categories: ”

• Identifiers/Contact Information:
These include your name, postal and email address, phone number, and unique identifiers that may identify your device or browser but not you by name.

• Location Data: data about the location of the device you use to access the Services as more fully described below.

• Commercial Information: Your purchase and usage history, and goods and service preferences, including payment information or photos you share from your devices.

INFORMATION Collected with Your Consent. We also may ask you for your consent to collect information in a particular interaction with you as described to you in those circumstances.

• Internet/Electronic Activity: Your geolocation information, IP address, web/app browsing and search history related to our Services, and information regarding your interaction(s) with the Services or KDP advertising.

• Profile Inferences: The inferences that we draw from your Personal Information and web activity to create a personalized profile so we can better identify goods and services that may be of interest.

We also work with various types of data that are de-identified or aggregated, and not reasonably capable of being associated with, or reasonably be linked, directly or indirectly, with you or your household. This data is not Personal Information.

Personal Information You Provide
KDP collects Personal Information when you choose to share it with us, such as:

Personal Information you provide when you create or use your account or other Services, or contact us. You must create a KDP account (“KDP Account”) to use certain Services, including the Keurig® App. A KDP Account as well as certain services we may offer such as subscription to our auto-delivery services require you to provide Personal Information so we can identify you and process your purchases, enable you to customize the Services to your liking (e.g., identify your brewing preferences), and so we can link your product preferences to your KDP Account. Also, when you contact us, we may monitor and record your conversation with the KDP representative (where permitted by law).

Personal Information you provide when you make a purchase. We collect Personal Information to process your purchases from us, and to provide you with the goods or services you ordered.

Personal Information you provide for customer support We collect your feedback and questions that you provide to us for customer support. In answering your questions, we may collect supporting data from your device.

Personal Information collected with your consent.We also may ask you for your consent to collect Personal Information in a particular interaction with you as described to you in those circumstances.

Personal Information Collected Automatically
Whenever you visit or interact with the Services, KDP, as well as third-party advertisers and/or service providers, may use a variety of technologies to collect Personal Information, such as:

Usage Information.We collect Personal Information about your activity on the Services, such as login date and time, features you use, and website, mobile app, and product interactivity.

Device & Device Usage Information.We collect Personal Information from and about the electronic devices that you use to access the Services, including IP address, device ID and type, device and app settings and characteristics, app crashes, advertising IDs, browser type and language, operating system, time zones, software version, domain name, identifiers associated with cookies or other technologies that may uniquely identify your device or browser, and information on your wireless and mobile network connection, like your service provider and signal strength. Our Internet connected devices, such as our smart brewers, may also include a camera designed to collect an image of the area where a pod is positioned within the brewer. This may be required to enable some connected Services and may also be used for diagnostic purposes to help ensure the brewer is working properly. Through this use, we collect Device Information associated with your KDP product, but not other Personal Information.

Location Information. We may collect data about the location of the device you use to access the Services (“Location Data”) using IP address, GPS, cellular towers and information from your mobile service provider, sensors that provide KDP with information on nearby devices, Bluetooth address, Wi-Fi access points, and information made available by you or others that indicates the current or prior location of your device. How we collect Location Data depends on how you use the Services.

Third Party Analytic and Advertising Technologies. KDP also may use third parties’ analytics and tracking tools, such as Google Analytics, and others, to help us track, segment, and analyze usage of KDP Services, and to help us or those third parties serve more targeted advertising to you on the Services and across the Internet. These tools may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or other technologies to collect and store information and may also combine such information with information that they collect from other sources. To learn more about your choices relating to advertising tracking, please see the “Your Choices and Opt Out” section below.

Personal Information Received from Other Third Parties
KDP collects Personal Information about you from third parties, such as social media platforms, public databases, or data vendors. This may include:

Personal Information collected when you connect with third parties through the Services. Certain Services may link with third-party platforms and plug-ins, such as social media platforms, plug-ins, and virtual assistants. When accessing the Services through an account with a third party, we may automatically receive certain information about you based on your registration and privacy settings on those third-party services, and use such Personal Information as described in this Privacy Policy.

Personal Information collected from data vendors. KDP may supplement your Personal Information with information that we obtain from third parties, such as public databases or data aggregators.

Personal Information collected through service providers. Our service providers also may collect and use Personal Information to assist us with our business operations. For example, our service providers may need Personal Information to help us analyze the performance of the Services, detect and prevent fraud, or to improve user experiences.

Combination of Information
We may combine the Personal Information we receive from and about you. As noted, we may also de-identify or aggregate information so it is no longer Personal Information.

KDP uses Personal Information – including Identifiers, Location Data, commercial or purchase-related information, Internet or other electronic network activity, and inferences drawn from your Personal Information in accordance with applicable data protection laws and this Privacy Policy for purposes including:

To administer your account and provide the Services to you, such as to:

• • Create and manage your KDP Account
• • Provide you with customer support and respond to your requests
• • Complete your transactions
• • Communicate with you about the Services, including order management and billing

To Ensure a Consistent Experience Across Your Devices, such as to:

• • Synchronize your usage across the various devices you use to interact with us
• • Personalize your experience with our Services

To Offer Promotions and Ads, such as to:

• • Administer sweepstakes, contests, discounts, or other promotions
• • Develop, display, and track content and advertising tailored to you on the Services and on other websites
• • Provide or contact you with customized Services content and offers from KDP or on behalf of our partners and affiliates

To Improve the services and develop new ones, such as to:

• • Administer focus groups and surveys
• • Conduct consumer research
• • Use demographic, profile and other analytics for analytical and demographic purposes (this processing may involve profiling – for example to create audiences based on demographic or location-based information for marketing and customization purposes)
• • Develop new features and services

To Prevent, Detect, and Fight Fraud or Other Illegal or Unauthorized Activities, such as to:

• • Enforce our Terms
• • Address fraud or alleged unlawful activity
• • Assist law enforcement
• • Conduct data analysis to better understand and design countermeasures against fraud
• • Protect the security and integrity of the Services and our business

To Ensure Legal Compliance, such as to:

• • Comply with legal requirements
• • Enforce or exercise our rights or those of third parties
• • Due diligence and required disclosures for corporate acquisitions and sales
• • Address problems with the Services or our business

Except as provided in this Privacy Policy, we will not disclose your information to any third parties without your consent. We may share your Personal Information as described below.

Sharing of Information by You
The Services offer many ways to find, enjoy, and share content. Any Personal Information you disclose in public areas on the Services or other third-party services may become visible to other individuals without restriction. Please exercise caution when disclosing Personal Information in public areas. If you provide any Personal Information to a third party while using our Services, the third party’s privacy policy will apply to your Personal Information disclosed to such third party.

Sharing of Personal Information by Us

With Our Service Providers. We use service providers to help us operate and improve the Services, such as for data hosting and maintenance, analytics, customer care, marketing, payment processing, order fulfillment, and security operations.

With Other KDP Businesses. We share your Personal Information with our subsidiaries and joint venture partners (collectively, “Affiliates”) who adhere to the privacy protections set forth in this Privacy Policy.

Promotions. If you choose to enter into one of our promotions (e.g., a sweepstakes or contest), we may disclose your Personal Information to service providers or the public in connection with the administration of such promotion, as required by law, as otherwise permitted by the promotion’s official rules and this Privacy Policy.

For Corporate Transactions. We may transfer your Personal Information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use Personal Information provided through the Services in a manner that is consistent with this Privacy Policy.

Legal Obligations; Safety. We may access and disclose your Personal Information to respond to subpoenas, judicial processes, or government requests and investigations, in connection with an investigation on matters related to public safety, or as permitted or otherwise required by law. We may disclose your Personal Information to protect the security of our Services, servers, network systems, and databases.

To Enforce Legal Rights. We may also share Personal Information (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and those of our users, business partners, or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding suspected illegal activity, fraud, or other wrongdoing.

With Your Consent or At Your Request. We also may share your information as disclosed to you at the time of collection.

We may use various practices and tracking technologies to allow us and third parties to develop and deliver targeted advertising on the Services and on websites or applications of third parties, and to analyze and report on such advertising you see.

Cookies. Certain parts of the KDP Services require cookies. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.

Opting out of targeted advertising using any of the below links does not mean that you will stop seeing digital advertisements. Rather, opting out means digital advertising will not be targeted to you based on your interests (as inferred from your online activities). Please refer to your browser’s or operating system’s website or “Help” section for more information on how to delete and/or disable your browser or operating system from receiving cookies or control your tracking preferences. On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising. To learn more about cookies, visit www.allaboutcookies.org. The Services use the following cookies:

Web Beacons. KDP also uses web beacons (also called pixel tags or clear GIFs). Some of KDP’s content and emails may contain embedded web beacons that allow a server to read certain types of information from your device, as well as allow us to count the number of people who have viewed content and to know when you opened an email message and the IP address of your device. Web beacons help KDP develop statistical information to provide better and more personalized content. To learn more about web beacons, visit www.allaboutcookies.org.

Access and Updates to Your Personal Information
For Keurig.com account holders, if you would like to correct your Account information or delete your profile information from your Account page, please visit the “Profile” tab in the “Account” section on a Site or in the App, visit the Settings screen, My Account and then choose the Profile option. You may also send your request via the Contact Us link. KDP reserves the right to request that you provide information that will enable KDP to confirm that you have the authority to correct or delete the profile information that you want corrected or deleted. KDP may not be able to correct or delete information shared with third parties. Pursuant to applicable law, we may be entitled to refuse to act on the request. California residents may exercise their rights to access or delete Personal Information according to the instructions in the “Information for Current California Residents” section below.

To opt out of targeted advertising, please visit the Digital Advertising Alliance or Network Advertising Initiative websites. To opt out of targeted advertising through mobile applications, please visit the AppChoices website. When you opt out through one of these websites, an “opt-out” cookie is stored in your web browser indicating that you do not want to receive targeted advertisements. If you delete cookies generally, you will need to opt out again.

We will retain your Personal Information consistent with applicable law and our retention policies. Such retention may include satisfying any legal, accounting, or reporting requirements. We also may aggregate or de-identify the information so that it no longer identifies you, in which case we may use this information indefinitely without further notice to you.

KDP takes precautions intended to help protect Personal Information that we collect and store. Unfortunately, no system or electronic data transmission is completely secure. Any transmission is at your own risk and we expect that you will use appropriate security measures to protect your information.

You are responsible for maintaining the security of your KDP Account. KDP will treat access to the Services through your KDP Account as authorized by you.

The Services are not directed to or intended for use by minors. We do not direct the Services to, nor do we knowingly collect any Personal Information from, children under the age of eighteen (18) (or age of majority of the individual’s relevant jurisdiction of residence).

We also may from time to time offer services that are co-branded (i.e., operated in partnership with an unaffiliated business). We and our co-branding partner may collect Personal Information on co-branded websites or services. Our processing of your Personal Information is subject to this Privacy Policy, but the processing of your Personal Information by a co-branding partner is subject to its privacy policy and practices, not ours.

The Effective Date of this Privacy Policy is stated at the top of this Policy. As we add new features, we may revise or supplement this Privacy Policy. If we change the Privacy Policy in a material way, we will provide appropriate notice. Your continued use of the Services after the Effective Date constitutes your acceptance of the Privacy Policy, as amended. As of the Effective Date, the amended Privacy Policy supersedes all previous versions of or agreements, notices, or statements about the Privacy Policy.

INFORMATION FOR CURRENT CALIFORNIA RESIDENTS (Effective January 1, 2020)

A new California law grants California residents the right to tell us not to sell their personal information. At Keurig Dr Pepper, we do not sell your data. However, as defined by California under this law, a “sale” of data includes how we share limited customer information among our affiliates who adhere to our privacy policy protections. We and our advertising partners also collect certain online information (such as cookies stored on your browser, the advertising identifier on your mobile device, and your IP address) and share that information with third parties to provide more relevant ads to you on our sites, apps, and on other sites that you visit.

In addition to the information provided elsewhere in this Privacy Policy, this section describes the types of personal information that, over the past 12 months KDP collects, uses, discloses, and may sell (as defined by the State of California) as described fully below.

Categories of Personal Information Sold
In the last 12 months, KDP has sold the following categories of Personal Information, namely for personalized advertising purposes:

• • Identifiers: sold to third party advertisers and internally with KDP’s Affiliates;
• • Geolocation data: sold to third party advertisers and internally with KDP’s Affiliates;
• • Internet/Electronic Activity: sold to third party advertisers and internally with KDP’s Affiliates; and
• • Profile Inferences: sold to third party advertisers and internally with KDP’s Affiliates.

We do not knowingly sell Personal Information about persons under the age of 16.

Categories of Personal Information Disclosed

In the last 12 months, KDP has disclosed the following categories of Personal Information for a business purpose (such as with our service providers who are restricted from using your Personal Information outside the scope of their services for KDP):

• • Identifiers: disclosed internally within KDP and with KDP’s Affiliates, as well as to service providers;
• • Geolocation data: disclosed internally within KDP and KDP’s Affiliates, as well as to service providers;
• • Commercial Information: disclosed internally within KDP and with KDP’s Affiliates, as well as to service providers’
• • Internet/Electronic Activity: disclosed internally within KDP and with KDP’s Affiliates, as well as to service providers; and
• • Profile Inferences: disclosed internally within KDP and with KDP’s Affiliates, as well as to service providers.

Your Rights

You have the right to access, delete, and opt-out of the sale of your Personal Information. KDP will not discriminate against you for exercising these rights, but may offer financial incentives to consumers who affirmatively allow us to collect and/or sell their Personal Information.

Access Request. You may make up to two requests per year for information as to:

• • The categories of Personal Information that we’ve collected and sold about you, or shared for a business purpose with our service providers;
• • The sources from which we collected such information;
• • The third parties with whom we’ve shared that Personal Information and to whom we’ve sold that Personal Information.
• • The business or commercial purpose for collecting or selling that Personal Information.
• • The specific pieces of Personal Information we’ve collected about you.

Deletion Request. You may request that we delete the Personal Information that we’ve collected from or about you. If we cannot delete all of your Personal Information, we will let you know the reason for non-deletion, such as if we need to complete a transaction for you, or for a legal reason.
KDP may take steps to verify your identity based on the information we have on file about you before responding to your Access or Deletion Request. You may need to provide your email address to be used for this purpose. We will confirm receipt of your request within 10 business days and will respond to your request within 45 calendar days unless we need additional time, in which case we will let you know.

Please click here to make an Access or Deletion request.

Opt Out Request. You have the right to opt out of KDP’s sale of your Personal Information to third parties, and to our Affiliates that do not share the same brand name, for their direct marketing purposes. This means that, if you opt out, going forward, we will not share your information with such third parties to use for their purposes unless you later direct us to do so. To effect the opt out, please click on the Do Not Sell My Personal Information link on our website footer or provided here. You may also submit a request by contacting Keurig at 866-901-BREW (2739) or click here or contact Dr Pepper brands at 800-696-5891 or click here. You may also submit a request by contacting our customer care centers as described above. We will comply with your opt-out request within 15 business days. Please note, this is a limited opt out that does not apply to previously-collected information, and you may still see advertising from us on websites you visit, but it would not be placed using any data that you have asked us not to share by opting out below. If you wish to receive information about your disclosure choices or stop communications from third parties, you will need to contact non-affiliated third parties directly. To opt out of online personalized advertising more broadly, you’ll need to refer to the opt-out options identified earlier in this Privacy Policy under “Your Choices and Opt Out.”

Agent Request. You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf, and that they are registered with the California Secretary of State to conduct business in California, or must demonstrate they have power of attorney pursuant to applicable probate law. KDP retains the right to request confirmation directly from the consumer confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity. An authorized agent shall not use a consumer’s personal information, or any information collected from or about the consumer, for any purpose other than to fulfill the consumer’s requests, for verification, or for fraud prevention.

Do Not Track. Some web browsers (including Safari, Internet Explorer, Edge, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have their online activity and behavior tracked. Not all browsers offer a DNT option, and DNT signals are not yet uniform. Many website operators, including KDP, do not respond to DNT requests or headers from some or all Internet browsers. As described above, we may use cookies or other technologies to deliver more relevant advertising and to link data collected across other computers or devices that you may use.