STARBUCKS PRIVACY STATEMENT
At Starbucks, we approach data and privacy as we approach everything we do: we put people first. We believe that taking care of you includes taking care of your personal data and privacy. Grab a cup of coffee and learn more below.
Last Revised: 20th June 2022
Overview
This Starbucks Privacy Statement describes the types of personal data that we collect, how we use it, how and when it is shared, and the choices and rights you have with respect to your personal data. It also explains how we communicate with you and how you can make requests or submit inquiries to us about your personal data. Thank you for taking the time to read and understand our data and privacy related practices.
1. Applicability and Scope
This Privacy Statement ("Statement") applies to the websites located at www.starbucks.ae, the Starbucks mobile applications available at www.starbucks.ae/app and any other websites or applications owned and operated by Starbucks brands or products that direct the viewer or user to this Statement. It also applies to the personal information we process when you visit one of our stores in the United Arab Emirates, the State of Kuwait or the Kingdom of Saudi Arabia.
Starbucks EMEA Limited (“Starbucks EMEA”) and Alshaya International Co. L.L.C. (“Alshaya”) which operates the Starbucks business in the above jurisdictions, are separate controllers in relation to information collected on the website, app and in store. Our corporate details can be found in Your Data Protection Choices and Rights section at the end of this statement. Alshaya has appointed a Data Protection Office who can be contacted at [email protected]
In this Privacy Statement, "we", "our" or "us" means Starbucks EMEA and Alshaya.
2. Updates to this Privacy Statement
This Statement went into effect on the "Last Revised" date noted near the top of this page. This Statement may be updated from time to time. When this is the case, you will be notified of any modifications to this Statement that might materially affect your rights or the way that we use or disclose your personal data prior to the change becoming effective by means of a message e.g., on the Website. We encourage you to look for updates and changes to this Statement by checking the "Last Revised" date when you access the Website and Application.
3. Personal Data We Collect
As you use our websites and mobile applications or visit one of our stores, we collect information about you and the services you use. The information we collect falls into three main categories: (1) information you voluntarily provide us; (2) information we collect automatically; and (3) information we collect from other sources.
Some examples of when we collect this information include when you browse or make a purchase on one of our websites or mobile application; create a Starbucks account; use our website or mobile application to purchase, reload or redeem a Starbucks Card; use the order and pay functionality in our mobile applications; or participate in a survey or promotion.
(a) Personal Data You Voluntarily Provide Us
Some information we collect is provided when you use our services, such as when you create an account, join Starbucks Rewards loyalty program; pay for products; or submit online forms.
You may also in some instances provide us information about other people, such as name, phone number and email address. If you choose to do so you must first obtain their permission to provide their personal information to us. The referred information will be used by us for the purpose of contacting the third party on your behalf to benefit from our app throughout our websites or mobile applications.
(b) Personal Data We Collect Automatically
Some information is collected automatically by us or by service providers performing business functions at our direction, including when you access our websites, download and use our Starbucks mobile applications, open emails we send or click certain links within them, or otherwise interact with our services. For example:
Purchasing Information – We collect information about your transactions in our stores, on our websites or via our Starbucks mobile applications including what products you purchase, how frequently you purchase them, any Rewards or promotions associated with a purchase, and the products you have placed on your “Wishlist" or “My Bag" for future purchase.
Device Usage and Location Information – We collect certain information using cookies to enable our systems to recognize your browser or device and to provide our services to you. For more information about cookies and how we use them, please read our [Cookies Notice].
Video Surveillance – Closed circuit video surveillance cameras are installed at some of our retail locations to monitor building security and assist in crime prevention, detection, and investigation, and to ensure the health and safety of our staff and visitors to our facilities.
Wi-Fi Service – Many Starbucks stores support providing you access to wireless internet (Wi-Fi) at no charge. We collect certain information as your MAC Address; your dynamic IP Address; your devices’ Browser agent; e-mail address; name; mobile number to provide this service to you. Please carefully review the terms of use listed on the activation page prior to accepting and connecting.
c) Personal Data We Collect from Other Sources
Some information we collect is from unaffiliated sources, including in some cases information that is publicly available, provided by or purchased from marketing business partners, or present on social media platforms.
For example, we may collect information you submit to a blog, a chat room, or a social network like Facebook or Twitter. We may also collect or license information about you from other companies and organizations, such as information aggregators or event or promotion co-sponsors, including to supplement information that we receive from you. In some cases, we receive information about you from affiliated entities, which we handle in accordance with this Privacy Statement. By gathering additional information about you, we can correct inaccurate information, enhance the security of your transactions and help prevent fraud, and give you product recommendations and special offers that are more likely to interest you.
4. How We Use Your Personal Data
We use your information for business and commercial purposes, including to provide the products and services you request, to perform customer service functions, for security and fraud prevention, for marketing and promotional purposes, and to perform website and mobile application analytics.
We rely on the following legal bases to process personal information:
(a) To Conclude or Perform Our Contract with You.
We process certain personal information when you access or use our services, for example, to:
Processing your purchases of products and services or requesting them;
Registration and verification of user accounts;
Promote our customer loyalty programs, such as Starbucks® Rewards;
Promote the functionality of the Website and the App, including payment-related functionality.
If you do not provide us with certain mandatory personal data when using our services, we will not be able to perform our contract with you (for example, if you do not provide us with your payment details, we will not be able to complete a purchase).
(b) For our Legitimate Business Purposes. We process certain personal information in our legitimate business interests, for example:
To Communicate With You. We process certain information in order to communicate with you in relation to your accounts, our services, our marketing, and your requests, including to communicate with you about orders, purchases, returns, services, accounts, programs, contests, and sweepstakes, respond to your customer service inquiries and requests for information, post your comments or statements on our websites, send you personalized promotions, content, and special offers, communicate with you about our brands, products, events, or other promotional purposes,
implement your communications preferences, such as sharing information with business partners so that they may email you about their promotions, products and initiatives; and
provide important product safety information and notice of product recalls.
For Research, Development, and Improvement of Our Services. We want to ensure that our website, mobile applications, and services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we process certain personal information, including to:
maintain, improve, and analyze our websites, mobile applications, ads, and the products and services we offer; and detect, prevent, or investigate suspicious activity or fraud.
To Enforce our Terms, Agreements, or Policies. To maintain a safe, secure, and trusted environment for you when you use our websites, mobile applications, and other services, we use your personal information to ensure our terms, policies, and agreements with you and any third parties are enforced.
(c) To Comply with Applicable Laws. We are required to process certain personal information under certain laws and regulations, such as tax laws, as well as to:
maintain appropriate records for internal administrative purposes as required by applicable law; and
comply with applicable legal and regulatory obligations such as to provide important product safety information and notice of product recalls), and to respond to lawful governmental requests, as needed.
(d) With Your Consent. If we have your consent to do so, we will process certain personal information, including to:
send you personalized promotions and special offers via email and other electronic means; and/or
to inform you about our brands, products, events, or other promotional purposes.
You can withdraw your consent at any time by modifying your promotional preferences in your Starbucks user account online, or by contacting us as described in the "Contact Us" section below. Withdrawing your consent does not affect the lawfulness of the processing prior to the withdrawal.
5. How We Share Your Personal Data
We share your information as needed to fulfill the purposes described in this Privacy Statement and as permitted by applicable law. This includes sharing between Starbucks EMEA and Alshaya among affiliated entities for internal business purposes, sharing with service providers to help perform business functions at our direction, sharing with your consent, sharing for marketing purposes, sharing as part of corporate transactions, and sharing to protect lawful interests.
We share personal information in the following circumstances:
(a) When We Work Together – We share information with subsidiaries and affiliated companies, including Starbucks Corporation as a separate controller based in the UK for administering our loyalty programs, process orders and requests, and expand and promote our product and service offerings.
(b) When We Work on Business Providers – We share your personal data with these service providers who provide support services to us, such as: services related to credit card payments, hosting and administration of the website and app, the platform for our customer card, customer care, Email and mail delivery, location mapping, delivery of products and services, abuse monitoring, analytics services, and conducting academic research. We contractually prohibit these service providers from storing, using or disclosing your personal data for purposes other than providing the agreed services to us.
(d) When We Work with Marketing Service Providers – We share information with marketing service providers to assess, develop and provide you with promotions and special offers that may interest you, administer contests, sweepstakes, and events or for other promotional purposes.
(e) When You Post on Our Websites – If you post information on a blog or another part of our websites, the information that you post may be seen by other visitors to our websites, including your username.
We also share personal data in a way that does not directly identify you. For example, in some cases we share information about your use of our websites and mobile applications in a manner that does not identify you or combine information about the nature or frequency of your transactions with similar information about other people and share the aggregated information for statistical analysis and other business purposes.
6. Starbucks Mobile Applications
In certain locations, we may offer the Starbucks mobile application (“Application”) for our customers’ use and enjoyment. For more information on the Starbucks® Application for iPhone® or Android™, please visit: www.starbucks.ae/app or your device’s mobile app store.
Use of the Application entails information collection in accordance with the Information We Collect section above and includes ways for you (the “User”) to control Application functionality, such as location services, setting push notification and in-app message preferences.
User Information -Through the use of an iOS, Android or other supported hardware device, some functionality of the Application requires the transmission of certain mandatory personal data provided by you to Starbucks, including:
Type of Personal Data | Purpose & Activity | Legal Basis |
Username and Password | For security reasons to verify your customer condition | Contract of Services linked to the Terms of Use |
E-mail Address | To communicate with under the scope of the ToS and for security reasons to verify your customer condition | Contract of Services linked to the Terms of Use |
Billing Address | Reconciliation purposes | Contract of Services linked to the Terms of Use |
Phone Number | To verify that your are our customer | Contract of Services linked to the Terms of Use |
Financial Information, such as payment card numbers or account numbers | To process your purchases | Contract of Services linked to the Terms of Use |
Information related to a Starbucks stored value card (“Starbucks Card”) | To process your purchases | Contract of Services linked to the Terms of Use |
This User Information is needed to purchase Starbucks products through the Application.
As described further below, certain optional personal data is also processed by us shared with Starbucks through the Application, including:
Type of Personal Data | Purpose & Activity | Legal Basis |
GPS location and Bluetooth-enabled iBeacons | To monitor the effectiveness of our marketing efforts and offer the MOP feature | Consent |
Advanced analytics information such as diagnostic, usage data, and user interactions | To understand your choices, habits and patters and deliver the right rewards to you | Consent |
Day and Month of Birth | To reward you that day with additional benefits as a loyal customer | Consent |
To enable our systems to recognize your browser or device and to provide the Application to you, we use cookies. For more information about cookies and how we use them, please read our Cookies Notice.
Linked Payment Method
You have the option to make your purchase securely and conveniently by making payment via your mobile device by linking a credit card, debit card or mobile wallet to your Starbucks account and use it to pay directly for your order through the App.
Controlling Application Functionality
Location Services - In order to use certain Application functionality, you must enable "Location Services" in the App - that is disabled by default in the Application - by going to your “Settings”.
Alternatively, you can set the permissions in your mobile device to allow communication of this information. More information about adjusting location services on iOS devices may be found here, and additional information on managing an Android device’s location settings may be found here.
If you allow for location sharing, additionally to the use of the MOP feature, your device communicates with us in ways that allow for us to customize your experience in and around Starbucks stores, to get directions and see what is available at nearby coffee houses, to monitor the effectiveness of our marketing efforts, to tailor messages based on your time and location patterns, and to limit the number of times you see a promotional message or offer.
Personal data collected using GPS or other location-based technologies is shared with us through the App on an optional basis.
User Responsibility
You are solely responsible for maintenance of the confidentiality and security of any User Information which you transmit from or store on a Device for purposes of the Application, including MOP, and for all transactions and other activities undertaken with any Starbucks Card registered in your name, whether authorized or unauthorized. You agree to immediately notify Starbucks of any unauthorized transactions associated with the Application including MOP or any other breach of security. Starbucks shall not be responsible for any losses arising out of the loss or theft of User Information which you transmit from or store on a Device or from unauthorized or fraudulent transactions associated with the Application.
Email Communications, Push Notifications, and In-App Messages
The Application allows all users to set preferences for receiving promotional email communications from Starbucks, receiving push notifications on your device, and receiving inbox messages. Email communications can be adjusted by you going to “Settings” > “Email Preferences”. Additionally, In-App messages can be adjusted also at “Settings” > “Notification Preferences” > “Inbox Messages”.
Promotional Communication Choices
You have control over your promotional communications preferences, mobile application functionality, cookie settings, and interest-based advertising preferences. You can opt out of receiving promotional emails and mailings by informing us of your preference at the time you sign up for a Starbucks account, by modifying your promotional preferences online in your account’s profile management section, or by following the “unsubscribe” instructions in the promotional emails we send you. Similarly, you may opt in to receive text messages, telephone calls and mailings.
Please note that if you opt out of receiving promotional communications from us, we may still send you transactional communications, including emails about your Starbucks accounts or purchases.
7. Your Data Protection Choices and Rights
Under certain circumstances, you have the right to:
Request Access
to obtain from us confirmation in writing as to whether or not personal data relating to you is being processed and information to the purposes of the processing, the categories of personal data concerned and the recipients or categories of recipients to whom the personal data are disclosed.
Request Rectification
of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request Erasure
of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Request Object to processing
where your personal data is processed for direct marketing purposes, including profiling to the extent that it is related to such direct marketing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request the Restriction of processing
that enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Personal Data Portability
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Exercise your Rights
If you wish to exercise any of the rights set out above, please contact, at [email protected] or post at Burj Alshaya Al Soor Street, Al Mirqab P.O Box 181, Safat 13002, Kuwait.
Lodge a Complaint
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint if you contend that there has been a contravention of the data protection legislation or an alleged breach of your rights under the law with the correspondent supervisory authority described here. We would appreciate the opportunity to first address your concerns and would welcome you directing an inquiry first to us at [email protected]
8. How We Protect Your Personal Data
We protect your information using technical, physical, and administrative security measures to reduce the risk of loss, misuse, unauthorized access, disclosure, or modification of your information. When you transmit highly sensitive information (such as a credit card number) through our website or in one of our mobile applications, we encrypt the transmission of that information using the Secure Sockets Layer (SSL) protocol. You are responsible for protecting your password(s) and maintaining the security of your devices.
9. Retention and Disposal of Your Personal
We store personal data as needed to accomplish the purposes identified in this Statement and to meet legal requirements, including record retention, resolving disputes, and enforcing our agreements. Our retention of your personal data is governed by applicable law. This storage period may extend beyond the term of your relationship with us.
As a general rule, we keep your personal data for only as long as it is needed to complete the purpose for which it was collected or as required by law. We may need to keep your personal data for longer than our specified retention periods to honor your requests or to comply with legal, regulatory, accounting, or other obligations. E.g., personal data contained in contracts, communications, and business letters may be subject to statutory retention requirements, which may require retention of up to 10 years. If applicable, any other personal data will in principle be deleted 6 years after the termination of the respective related contractual relationship between you and us, if applicable).
When personal data is no longer needed, or in any event, after legal authority to retain it has expired, personal data will be destroyed, in accordance with local law and pursuant to procedures established in relation to the relevant system or process.
10. Children
We do not intend for our websites or online services to be used by anyone under the age of 13 however we cannot prevent certain users, including children, from fraudulently representing their age in order to gain access to the Site or an App. If you are a parent or guardian and believe we may have collected information about your child, please contact us immediately as described in the “Contact Us" section of this Statement. For more information, please see our Terms of Use.
11. International Transfers
Your personal data may be transferred to, stored, and processed by Starbucks in a country other than the one in which it was collected, including the United Kingdom and the Republic of Ireland. It may also be processed by staff operating outside the UAE who works for Alshaya in the State of Kuwait or India, Starbucks or for our third-party service providers. In such cases, we will take appropriate steps to ensure an adequate level of data protection of the recipient as required under the correspondent data protection regulation, including by putting in place standard contractual clauses that have been approved by the Supervisory Authority. You may obtain a copy of these clauses and further details on Starbucks third-party service providers by directly contacting Alshaya or Starbucks EMEA Limited at [email protected]
12. Contact Us
We welcome your questions, comments, and concerns about privacy. Alshaya Customer Care can be contacted online at [email protected]