Privacy Notice

Privacy notice


Privacy Notice (“Notice”) – Nigerian Bottling Company

Introduction

Nigerian Bottling Company (‘NBC’, 'Our', 'Us', 'We', or 'Company') is committed to protecting the privacy and security of the personal data of its data subjects: employees, suppliers, customers, consumers, relevant stakeholders, and visitors to this website. In line with the provisions of the Nigeria Data Protection Act (NDP Act), 2023, and other applicable Data Privacy laws and regulations, this Privacy Policy explains how we collect, use, disclose, store, restrict, erase or destroy and generally manage your personal data.

What Is Personal Data?

Personal data is information about an identifiable individual, as defined by applicable law, such as name, email address and telephone number.

In general, you can visit this website without telling us who you are or revealing any information about yourself. Our web servers collect the source IP addresses, for IT reasons, enabling you to connect to our platform providing you with our services, not the email addresses, of visitors. In addition, there are parts of this website where we need to collect personal data from you for a specific purpose, such as to provide you with certain information you request and where requested to register you to our website.

Our Guiding Principles on Data Processing

Personal data collected by NBC will be;

  1. processed in a fair, lawful and transparent manner;
  2. collected for specified, explicit, and legitimate purposes, and will not be further processed in a way incompatible with these purposes;
  3. adequate, relevant, and limited to the minimum necessary for the purposes for which it was collected or further processed;
  4. retained for not longer than is necessary to achieve the lawful bases for which the personal data was collected or further processed;
  5. accurate, complete, not misleading, and, where necessary, kept up to date having regard to the purposes for which it is collected or is further processed; and
  6. processed in a manner that ensures appropriate security, including protection against unauthorised or unlawful processing, access, loss, destruction, damage, or any form of data breach.

Furthermore, We are committed to ensuring accountability, demonstrating duty of care to you and upholding data Confidentiality, Integrity and availability.

Consent of Data Subject

By providing your personal data to us, you signify your acceptance of our Privacy Notice and agree that we collect, use, and disclose your personal data as described in this Privacy Notice. If you do not agree with this Notice, please do not provide your personal data to us. 

Minor Consent

If you are aged under 18, please get your parents’ or guardians’ permission before you provide any personal data to us. Users without this consent should not provide us with their personal data. WE do not knowingly collect personal data of children under 18 without parental or guardian consent. Where services are offered to minors, lawful safeguards will be applied.

Consent Withdrawal

Once you provide consent, you may withdraw the consent at any time by contacting us at DataProtectionOffice@cchellenic.com or accessing this link: DSAR. Note that consent withdrawal will not affect the lawfulness of processing carried out based on consent before withdrawal.

Rights of Data Subjects

  1. Right to be Informed.
  2. Right of Access to your personal data.
  3. Right to Rectification of the personal data that We hold about you.
  4. Right to Object to Processing.
  5. Right to Data Portability.
  6. Right to request erasure of your personal data “right to be forgotten”.
  7. Right in Relation to Automated Decision Making (which essentially entitles you to human oversight).
  8. Right to lodge complaints with the NDPC at https://ndpc.gov.ng/.

Our Scope of Data Processing

Below is a table containing a non-exhaustive list of the types of personal data we collect, the purpose and the lawful bases for processing them:

 

Data Subject

Collected Data

Purposes for the collection

Justification of the collection

Visitor of our Website

IP address, domain name, your browser version and operating system, traffic data, location data, web logs

to measure the number of visits, average time spent on the site, pages viewed

legitimate interest to measure the use and to improve the content of our website

name, email address received from the visitor of our website

to provide you with information about our promotional offers, news, events (newsletters and other publications), the Investor Relations or copies of our Annual Reports and to administrate subscription-service records (to a corporate webcast service or to an email alert service)

your prior consent by ticking the appropriate box when providing your personal data to us

name, address, telephone, fax number, email address; received from the visitor of our website

to response to your inquiries or to process your requests in relation to your information

to take appropriate steps at your request prior to entering into a contract

Business Customer/ Supplier

name, address, telephone, fax number, email address, tax data, bank account; received from our business customer/supplier.

for sales and supply of goods and services order taking, delivery execution, invoicing, payment allocation, to provide or receive the requested goods and services and for marketing and promotional initiatives.

performance of our mutual contractual obligations

name, address, telephone number, email address received from our business customer/supplier

for maintenance of the business relationship and evaluation of the level of our services (such as through customer satisfaction surveys, etc.)

our legitimate interest to maintain our business relationships, to evaluate the customer experience, identify improvement areas for the performance and development of our business and proceed with corrective actions if needed.

name, telephone number, email address received from our business customers

To contact our customers for marketing and promotional purposes/initiatives relating to products/services offered by us

our legitimate interest for the performance and development of our business or consent (as needed).

creditworthiness, criminal/fraudulent activities, ID documents, credit ratings, politically exposed person, and sanctions lists.

anti-bribery, anti-money laundering, sanctions, Know Your Customer, Credit and Anti-Fraud Checks.

compliance with legal obligations, contract performance, consent (as needed), legitimate interest.

Potential Business Customer / Potential Supplier

name, address, telephone, fax number, email address, tax data, bank account; received from our business customer/supplier

For pre-contractual evaluations & assessments of potential customers and suppliers (e.g. Tender process) and for taking steps at your request before entering into a contract with us

our legitimate interest or in order to take steps at your request prior to entering into a contract with us.

Name, telephone number, email address

To contact you for marketing and promotional purposes/initiatives relating to products/services offered by us

Your prior consent

creditworthiness, criminal/fraudulent activities, ID documents, credit ratings, politically exposed person, and sanctions lists.

anti-bribery, anti-money laundering, sanctions, Know Your Customer, Credit and Anti-Fraud Check.

compliance with legal obligations, consent (as needed), legitimate interest.

Contact Person of the Customer/ Supplier

name, address, telephone, fax number, email address, SMS notification preferences, personal preferences; 

to contact the customer/supplier for business purpose (e.g. order taking, service request), for maintenance of the customer relationship, providing updates to customers for marketing and promotional initiatives.

performance of our mutual contractual obligations or based on our legitimate interest for the performance and development of our business or consent (as needed).

Consumer

name, address, telephone, address, fax number, and email address. ID number and Tax. Code

Engaging consumers in advertising or promotional initiatives

performance of our services on the basis of the terms of advertising or promotional initiatives

name, telephone number, address, and email address

to respond to reported issues with products or questions on our products on the toll-free consumer service telephone line

legitimate interest to ensure the quality and safety of our products, provide our services and ensure our consumers satisfaction

Job Applicant

 

 

 

Name, address, telephone, email address, professional qualifications, experience, and education; submitted by the job applicant

candidate management, to assess your application and to contact you via phone or email

 legitimate interest to assess your application prior to entering into an employment contract with us

Consent in order to retain your data for other job opportunities

Publicly available data of the job applicant on contact information, social links, professional qualifications, experience, and education

Candidate management, to enhance, validate and update applicant data to ensure validity and completeness

Consent

Video interview recording

To conduct interview process

Consent

Results of tests and assessments during the recruitment process

Candidate management, to conduct  evaluation of individual skills and competencies

Consent

Startup founder / Startup employeesteam lead name, email address, professional social media link and locationTo offer implementation support to startups, to help startups grow and scale through cooperation with our business unitsTo assess investment and/or partnership opportunity
name, title, and short bio of selected core team members
financial data of the startup

For further clarifications as per your application to Coca-Cola Hellenic Bottling Company AG (“CCHBC“) team, kindly access our Global Candidate Privacy Notice.

Transfer of Data to Third Parties and Countries

The personal data you provide to us will be held in a Data center hosted in Crawley, UK, by a company named Rackspace, whose secondary site is in Ireland. We may share your personal data with authorized third parties (including CCHBC group of companies, service providers, business partners, government bodies, law enforcement agencies) we engage to process data on our behalf, some of whom are located outside Nigeria, for the purposes and justifications set out in this policy.

Transfer of personal data outside Nigeria would be in accordance with the provisions of the Nigeria Data Protection Act 2023 (NDPA), the General Application and Implementation Directive 2025 (GAID) and other applicable laws and regulations.

Unless required to do so by law, we will not otherwise share, sell or distribute any of the personal data you provide to us without your consent.

Finally, if our business enters into a joint venture with or is sold to or merged with another business entity, your data will be disclosed to our new business partners or owners.

Categories of the recipientPurpose of the sharing
companies within the Coca-Cola Hellenic group of companies and/or third-party service providers that process data on our behalfto provide our products and services
any third-party service providers any subsidiary/affiliate of Coca‑Cola HBC involved by us in the provision of the services you requested or requested by us for the purposes above listedperformance of the services you requested
business partnerperformance of the services you requested
government bodiesto fulfil a legal obligation
law enforcement agenciesto fulfil a legal obligation
successors in title to our business and suppliersperformance of the services you requested
credit reference agencies, fraud prevention agencies, companies within the Coca‑Cola Hellenic group of companies and/or third-party service providers that process data on our behalfanti-bribery, anti-money laundering, sanctions, Know Your Customer, Credit and Anti-Fraud Check

Personal Data Security

We employ strict physical, electronic, and administrative security measures to protect your data from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage both online and offline. 

Data Retention

We will retain your data for as long as necessary to fulfil the said purpose of the collection and/or as long as legally required.

Caveat on Website Links

Our website contains links to other websites which are outside our control and are not covered by this Privacy Notice. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their Privacy Policies, which may differ from ours. We do not accept any responsibility or liability for their policies or processing of your personal data. We encourage you to read the privacy and cookie notices and terms and conditions of any linked, referenced, or interfacing websites you enter before you submit any personal data to such third-party websites.

Remediation

In the event of a data breach, We will promptly notify the NDPC within 72 hours and affected data subjects without undue delay, in accordance with Section 40 of the NDP Act 2023.

Alteration of Privacy Policy

WE reserve the right to review and update this Privacy Policy periodically to reflect regulatory, technological, or organizational changes. WE will provide notice to you on this website of any major changes for at least 30 days following the change and, where appropriate, through email notification.

Contact Us

For questions, complaints, or requests relating to this Privacy Policy, please contact: 

Data Protection Officer (DPO)
Nigerian Bottling Company Limited
Kings Towers 24, Glover Road, Ikoyi, Lagos, Nigeria
Email: DataProtectionOffice@cchellenic.com
Dedicated Online Link: Web Form