STARBUCKS PRIVACY STATEMENT
Last Revised: 17/04/18
This Privacy Statement ("Statement") applies to applicant employment data collected via the Starbucks careers website at www.starbucks.co.uk/careers and www.starbucks.nl/careers. The website will provide information about the Starbucks group, working at Starbucks, roles within Starbucks, Starbucks partner case studies and shall also advertise live vacancies.
Please note that this Statement is separate and in addition to the privacy statement that may apply to the use of your personal data should you be offered employment by a Starbucks entity (or a Starbucks Licensee if applicable). All data you submit or that is obtained by us in relation to your use of this website and the services will be treated in accordance with this Statement.
In this Statement, the terms "Starbucks", "we", "our" and "us" refers to the Starbucks entities in the table below (being Starbucks group companies) and any Starbucks entity to whom you submit an application, in each case acting in its capacity as data controller. This includes the following Starbucks entities and its respective subsidiaries and affiliated companies, who can be contacted at the details in Section 13 below:
|UK||Starbucks EMEA Limited|
|Starbucks Coffee Company (UK) Limited|
|Netherlands||Starbucks Manufacturing EMEA B.V.|
|Starbucks Coffee EMEA B.V.|
|Starbucks Coffee Netherlands B.V.|
The term “your device” refers to any computer, tablet, smart phone or other device you are using to access our website. Our website may from time to time contain links to websites that are owned and operated by other companies. This Statement does not apply to websites and services that are owned and operated by third parties.
This Statement came into effect on the date indicated at the top of this webpage. We may update this Statement from time to time. If we make changes, we will post the updated Statement on this page and change the date at the top of this Statement webpage. We encourage you to look for updates and changes to this Statement by checking this date when you access our website. We will notify you of any modifications to this Statement that might affect the way we use or disclose your personal information prior to the change becoming effective by means of a message on this website.
PART I - GENERAL INFORMATION
- Information We Collect and Legal Basis for the Collection
As you use our website we collect information about you and the services you use for the purposes described below in Section 2 of this Statement. The information we collect falls into four different categories: (1) information you give us; (2) information we collect from you automatically; (3) information we collect from other sources; and (4) information we collect from your current Starbucks employer. Some examples of when we collect this information include when you visit our website, use our website to submit an application for employment or participate in a survey (where applicable).
- Information You Give Us
Some information we collect is provided by you when you use the website and our services. This may include, for instance, your first and last name, username, password, email address, postal address, phone number, demographic information (such as your gender), availability for work, job experience and history, educational background, skills, interests, position(s) you are interested in, and any other information you choose to give us in your C.V., cover letter or similar. Where you provide us with third party details for reference purposes, you confirm that you have in advance sought such third-party authority to share their personal data with Starbucks. The data you provide when using the website shall be saved upon you completing each page of the website.
- Information We Collect Automatically
Some information is collected by us automatically, including when you access our website or otherwise use our services. This information, whose collection might require your consent, includes:
- Location Information - As part of your application process you might be required to provide your geo-location in order to allow us to relocate you in case of a specific request or to direct you towards relevant vacancies
- Information We Collect from Other Sources
Some information we collect is publicly available. For example, where permitted by law in the relevant territory and with your prior consent, we may collect information you submit to a blog, a chat room, or a social network like Facebook, Twitter, LinkedIn or Google+. We may also collect information about you from other companies and organisations. By gathering additional information about you, we may correct inaccurate information, give you job recommendations that are more likely to interest you (provided you have consented) and improve your applicant experience.
- Information We Collect from Your current or previous employer
Some information we collect from your current or previous employer. For example, Starbucks may contact your current or previous employer for reference purposes and/or to verify information about you and your employment history subject to your prior consent.
- How We Use Your Information and on What Legal Basis
We may use the information we collect about you for the following purposes:
- to process your application;
- to communicate with you about your application and/or any positions that may be of interest to you subject to your prior consent to do so;
- to respond to your enquiries and requests for information;
- to maintain appropriate records required under applicable laws and for internal administrative purposes;
- to detect, prevent, or investigate security breaches or fraud and protect the rights of Starbucks and others, in particular to: (i) protect, enforce or defend the legal rights, privacy, safety or property of Starbucks, our company subsidiaries or affiliates or their employees and contractors; (ii) protect the safety, privacy and security of users of Starbucks services; (iii) comply with the law or legal process; and (iv) respond to requests from public and government authorities;
- to conduct applicant and employment-related statistical evaluation in an aggregate manner and record keeping;
- to complete a merger or sale of assets. In this respect, if Starbucks sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger or transfer of all or a material part of its business, Starbucks may transfer your information to the party or parties involved in the transaction as part of that transaction;
- within the limits provided by the provisions on cookies, and other similar technologies below, to: (i) maintain, improve, and analyse our website; and (ii) facilitate the functionality of our website; and
- to perform aggregated analytics to improve the applicant and partner experience.
The disclosure of your personal data for the purposes indicated in paragraphs 2.a) to f) of this Statement is compulsory since it is necessary for the provision of the requested service and the refusal to provide the information for the purposes indicated in paragraphs 2.a) to f) would make it impossible for Starbucks to provide the required services. The processing of information for the purpose of paragraph 2.g) is not compulsory and is performed in compliance with applicable laws and the legitimate interest of Starbucks and its counterparties to perform such transactions, adequately balanced with your interests. You can object to such data processing by contacting us through the modalities indicated in Section 13 below, but if you object to such data processing activity, your data cannot be used for this purpose.
The disclosure of your personal data for the purposes of paragraphs 2.h) and i) is discretionary, save for the technical cookies indicated in the Sections below which are mandatory. The refusal to provide the information requested for the purpose of paragraph 2.h) above may result in the provision of a lower level of service, while the refusal to provide the information requested for the purpose of paragraph 2.i) above would prevent us performing aggregated analytics.
With regard to the above-mentioned purposes, your information may be processed by Starbucks by way of electronic and non-electronic means.
- How We Share Your Information
We may share your information with the following categories of entities outside of Starbucks situated both in the EEA and, within the limits of Section 12 below, outside the EEA, which process your personal data in their capacity of data controller or data processors depending on the circumstances and in the following circumstances:
- When We Work Together – We may share information between and among Starbucks Corporation, its subsidiaries, its licensees and/or affiliated companies for the purposes of management, analysis and decision making, and for use by those companies for the other purposes described in Section 2 above.
- When We Work with Service Providers – We may share your information with service providers that provide us with support services such as technology service providers, applicant management, skills and background analysis, employment administration, and to communicate with you and for other services such as website hosting, email and postal delivery, marketing of new candidate roles or analytics services. We require the companies to refrain from collecting, using and disclosing your information except when they are performing work for us or when the disclosure of your information is required by law.
- When We Work on Business Transactions – If we become involved with a merger or another situation involving the transfer of some or all of our business assets, we may share your information with business entities or people involved in the negotiation or transfer.
- When Sharing Helps Us Protect Lawful Interests – We may disclose your information if we believe that the disclosure is required by law, if we believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that the disclosure will help us protect the rights, property, or safety of Starbucks or our customers or partners.
- When You Give Consent – We may share information about you with other companies (where applicable) if you give us permission or direct us to share the information
- When the Information Does Not Identify You – We may share your information in an anonymous format. For example, we may share information about your use of our website in a manner that does not directly or indirectly identify you or may combine information about you or the use of the services with similar information about other people and share the aggregated information for statistical analysis and other business purposes in a way that does not link your information to you.
- To Collect Information on How Our Websites and Services Are Used – We allow certain service providers to use the information collected on our website and via our services to help us learn about our audience and how people use our website. The companies that use this information for this purpose do not match the information to individual users, nor does it cross or enrich the data collected with other data. In other words, statistical information collected by third parties regarding website usage or performance is not matched or linked to you.
Starbucks has appointed as external data processors, Jupiter Advertising Limited and Oracle America, Inc to provide services in relation to its recruitment website. A list of all the external data processors appointed by Starbucks is available at its registered office.
- What are Your Rights with regard to Your Personal Data?
Where your personal data is collected via this website and/or our services by a Starbucks entity, you have the right at any time to:
- obtain confirmation as to whether or not such personal data exists and to be informed of its content and source, verify its accuracy or request integration, updates or amendments;
- request the deletion, conversion to an anonymous form or restriction of such personal data processed in breach of the applicable law; and
- oppose its processing, in all cases, for legitimate reasons.
You may also revoke your consent, at any time, to the receipt of any marketing communications and to profiling activities.
In addition to the above, from May 25th, 2018, the date of applicability of the General Data Protection Regulation, you will also have the right set out in Section 14(b) below.
In order to exercise the rights above, you can contact us as described in the "Contact Us" Section of this Privacy Statement. In your request, please include your email address, name, address, and telephone number.
- Cookies and Similar Technologies
Cookies – Cookies are small data files that are sent from a website’s server and are stored on your device’s hard drive either for only the duration of your visit ("session cookies") or for a fixed period of time ("persistent cookies"). Cookies contain information that can later be read by a web server.
These and similar technologies are used for the following purposes:
Services and Functionality – Some of these technologies are required to allow you to access and use our website and the various services and functionality we offer. Without these technologies some of the services and functionality on our website would not work properly.
Performance Monitoring – Some of these technologies help us analyse and estimate traffic and assess the volume of use of services and functionality on our website. They show us how visitors and candidates interact with our website, whether there are any errors, the degree to which certain web pages, applications, services or functionality are accessed and used and how they are performing or operating. When these technologies are used for performance monitoring, no information that identifies you is collected and these technologies are only used to help us improve how our website and understand user interests.
User Convenience – Some of these technologies enhance the ease of use of our website and the services and functionality they make available by accelerating load and refresh times and remembering information that you have provided on prior visits to our website or when you last used a website service or functionality. For example, a cookie may remember your username to save you time in entering this information when you log in to your account.
- Retention of Your Data
Your information which is collected via this website and/or our services by a Starbucks entity that is not your current employer, will generally be retained for six (6) months from the date of your application or as long as your user profile and account is active or as required by law or as needed to provide your requested services. You have the opportunity to review Starbucks' policy regarding the retention, disposition, access and confidentiality of the information collected in the application process before applying for employment with that Starbucks entity.
PART II - YOUR CHOICES
- Communication Choices
In order for us or our affiliated companies or licensees to successfully process your job application, we (or where applicable our affiliated companies or licensees) shall be required to communicate with you in relation to your job application only, using the contact details you provide to us.
- Cookies and Similar Technologies
In addition to the information provided above, you may be able to reject cookies by adjusting the appropriate settings in your browser. Each browser is different, but many common browsers (Internet Explorer, Chrome, Firefox, and Safari) have preferences or options that may be adjusted to allow you either to accept or reject cookies and certain other technologies before they are set or installed or allow you to remove or reject the use or installation of certain technologies altogether. If you want to learn the correct way to modify your browser settings, please use the Help menu in your browser or visit the following links:
Google Chrome: https://support.google.com/chrome/answer/95647
Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
- "Do Not Track" Technology
Subject to this Privacy Statement, some newer web browsers have a "Do Not Track" preference that transmits a "Do Not Track" header to the websites you visit with information indicating that you do not want your activity to be tracked. We currently do not respond to browser "Do Not Track" signals.
- How to Manage Your Account Information
Information can be changed or removed from Starbucks accounts where required by law. As required by law, there are instances whereby we are unable to delete an account completely.
- Use by Minors
We do not intend for our website or online services to be used by anyone under the age of sixteen (16). If you are a parent or guardian and believe we may have collected information about your child, please contact us as described in the "Contact Us" Section of this Statement.
- Transfer of Data Abroad / EU-U.S. Privacy Shield
The information you provide us is stored and processed on servers owned by Starbucks and our respective service providers located throughout the European Economic Area (EEA). Your personal data may be transferred to countries within the European Economic Area or outside the EEA and in particular to the U.S.A whose data protection laws may be less stringent than your country’s laws. Starbucks will ensure that appropriate and suitable safeguards are in place to protect your personal data and that transfer of your personal data is in compliance with applicable data protection laws (and in particular article 46 of the General Data Protection Regulation) and this Statement.
You have the right to request a copy of your personal data, to know where your personal data is stored, or to request rectification to any inaccurate data we hold by contacting Starbucks at the address indicated in this Statement.
We may use certain service providers to process your data in relation to your application. Starbucks has appointed as external data processor, Oracle America, Inc, to provide services in relation to its recruitment website, with its data centre based in U.S.A. Where we use certain service providers in this manner, we may use specific contracts (or contractual clauses) approved by the European Commission which give personal data the same protection it has in Europe.
Where Starbucks transfers to or processes your data in the U.S.A note that Starbucks Corporation participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Starbucks is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List here: https://www.privacyshield.gov/list.
Starbucks is responsible for the processing of personal data it receives, and subsequently transfers to a third party acting as an agent on its behalf, under the Privacy Shield Framework. Starbucks complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Starbucks is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Starbucks may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website here: https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
- Contact us
We welcome your questions, comments and concerns about privacy. You can contact Starbucks Customer Relations in the UK by email at firstname.lastname@example.org or by telephone at 020 8834 5050. In the Netherlands, you can contact Starbucks Customer Relations by email at customercareNL@starbucks.com .
- What changes with the General Data Protection Regulation 679/2016/EU?
From May 25th, 2018, the date of applicability of the General Data Protection Regulation, the following provisions will apply in addition to those listed above:
- Data retention of your personal data
We will retain your information only for the period necessary to fulfil the purposes for which the data was collected as outlined in this Statement; in particular:
- Information collected for the purposes of Section 2(a) to (e) of this Statement
by a Starbucks entity is retained for six (6) months from the date of your application or for as long as your user profile and account is active or as otherwise required by law;
- Information collected for the purposes of Section 2(g) is retained for a period that changes depending on the cookie involved as indicated in the relevant policy;
At the end of the retention period your personal data will be either cancelled, anonymized or aggregated.
- Additional rights
In addition to the rights as indicated in Section 4 of this Statement, you will also have the right at any time to:
- request that Starbucks limits the processing of your personal information where:
- you contest the accuracy of the personal information until we have taken sufficient steps to correct or verify its accuracy;
- the processing is unlawful but you do not want us to erase the data;
- we no longer need the personal information for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; or
- where you have objected to processing justified on legitimate interests grounds pending verification as to whether Starbucks has compelling legitimate grounds to continue processing;
- object to the processing of your personal information;
- request the erasure of your personal information without delay;
- request the data be made portable (when we are relying upon your consent or the fact that the processing is necessary for the provision of the Starbucks services and the personal information is processed by automatic means); and
- lodge a complaint with the relevant supervisory authority for the Starbucks entity that is processing your data.
- Data Protection Officer
In light of the processing activities carried out by Starbucks as set out in this Statement, Starbucks may through this Statement and/or on the applicable website notify of the contact details of the data protection officer, should it reach the conclusion that it is required to do so under the terms of the General Data Protection Regulation.