FIFCO
 PRIVACY NOTICE
 

As the data controller, Distribuidora La Florida S.A., with legal ID 3-101-295868, part of the Florida Ice and Farm Company S.A. Economic Group, is committed to respecting your privacy rights when using our digital platforms (such as our websites, mobile applications, social media pages, or any online forms for registering for our activities) and when contacting us by email.

This privacy policy is intended to inform you about how Distribuidora La Florida S.A., located in Heredia, Llorente de Flores, 500 meters south of Cervecería Costa Rica ("FLORIDA"), and its subsidiaries (collectively, “FLORIDA”, “we”, “our”, or “us”) collect, store, use, and process your personal data ("personal data") provided through any digital platform operated by FLORIDA (the "digital platforms").

By using FLORIDA's services, you agree to these terms. Please read them carefully.

Table of Contents

  1. What types of personal data do we collect?
  2. For what purposes do we use your personal data?
  3. What happens if you refuse to provide your personal data?
  4. Why and to whom do we transfer your personal data?
  5. How long do we keep your personal data?
  6. How do we protect your personal data?
  7. What are your rights?
  8. How do we handle children's personal data?
  9. How can you contact us?

1. What types of personal data do we collect?

Personal Data is collected solely for the purposes set forth in Section 3 below, and whenever you participate in any events, activities, or services offered through our Digital Platforms. The type and amount of information collected for the aforementioned events and services may be updated and vary depending on FLORIDA's activities.

Subject to applicable legal requirements, we may use various technologies to collect and provide information about how you access and use our Digital Platforms. We may also use demographic information (such as your age, gender, and areas of interest, if available) about users of our Digital Platforms, which we may obtain from third parties or through social networks you use ("Usage Information"). Usage Information may include the pages you viewed, the time you viewed them, what beverage or other content you accessed or provided, the language used, including demographic information about you, and the pages you visited before viewing the current page, among other things.

2. For what purposes do we use your personal data?

The type of information we collect depends on how you interact with us. We collect your personal data for the following purposes:

• The Information may be used by the Company for commercial purposes, including maintaining a record of my consumption patterns, sending commercial information, advertising, and serving as contact information for informational purposes, statistical analysis, following up on my issues with the company, transferring that data internationally, among others. This information could relate to the brands I purchase from FLORIDA, as well as products I have not purchased. • To respond to your service requests or execute a contract: When you register or subscribe to our digital platforms (mobile apps, websites, social media, etc.), your personal data is used to provide the functionalities and services you have subscribed to and offer you the benefits and privileges derived from your registration (e.g., receiving communications you selected during registration, being invited to events, participating in contests, etc.); • To send you operational or administrative communications (e.g., a confirmation email when you register [or cancel your subscription] for a service or functionality), as well as various notifications about services (e.g., updates to our privacy notices, interruption of functionalities, or programs on our digital platforms, modifications affecting our online services or IT support policies, notifications related to other modifications, etc.); • To allow us to send you marketing communications, as long as you have given us your consent. • In addition to the purpose for which you provided your personal data, we may also ask for your consent (e.g., by checking a box) to use your personal data for a different activity or service than the main one for which you made your request. For example, if you sign up for a contest or any other promotional activity, we may also invite you to subscribe to newsletters or alerts sent through our digital platforms or other websites. If you agree to receive our targeted advertising, emails, and SMS, we will use your personal data for this purpose. Because it is also in FLORIDA's legitimate interest to provide you with a better service:

  • As long as we have your consent (when required), we may combine, update, or regroup your personal data collected through our digital platforms with other data received from third parties or external sources. For example, we may combine purely demographic data or survey data (such as age, gender, family information, other interests, etc.) not related to your personal data with personal data collected through our offerings (e.g., when you register an account).

We may use this combined data and/or the previously mentioned demographic data for our demographic and marketing studies to continuously improve, personalize, and tailor the products and services we offer, in order to meet your needs. Some tools we use may involve automated decision-making processes according to the conditions permitted by applicable legislation.

• We will ensure that your personal data is kept accurate and updated or completed with the additional information you have provided. We will also strive to avoid duplicates in our database by verifying each of your interactions with us and/or our affiliates, and checking whether your personal data is still accurate or needs to be completed or updated with additional information you have provided. We may analyze your activities and browsing habits on our digital platforms to better understand your preferences and interests and adapt our communications to your tastes, unless you oppose this as stated in this Policy.

3. What happens if you refuse to provide your personal data?

If you refuse to provide the personal data we request, you may not be able to participate in certain activities, enjoy certain personalized functionalities, or have access to the digital platforms and special services we offer. However, you are not obligated to provide your personal data to browse our digital platforms and learn about FLORIDA and our products. We will always indicate which personal data is required to enjoy a service.

4. Why and to whom do we transfer your personal data?

a. To companies within the Florida Ice and Farm Company S.A. Economic Group: For the purposes mentioned in Section 2, FLORIDA may share your personal data within the Florida Ice and Farm Company S.A. Economic Group.

Various officers, employees, representatives, and advisors (both external and internal) of FLORIDA will have access to the information for the same purposes. This information is provided voluntarily. However, if I refuse to provide it, the Company may refuse to provide me with certain services.

b. To third parties: We may transfer your personal data to third parties, but only in the following cases:

  • For marketing purposes, provided we have your consent.
  • For assistance purposes: We may engage service providers, agents, or contractors to provide support and maintenance services for our digital platforms and to help us manage these platforms or the various programs, promotions, and features they contain. These third parties are committed to providing your personal data with the same levels of security as FLORIDA, and when required by law, these commitments will be documented in writing in a contractual agreement.
  • For joint and co-sponsored programs for promotional purposes: When we carry out joint or co-sponsored promotional activities on our digital platforms in collaboration with other companies or any trusted third party, and during these activities, we collect and process your personal data, we may share it, provided we have obtained your consent when required by law. If your personal data is collected by a company other than FLORIDA (or transferred to it) in the context of this promotional activity, we will inform you at the time the data is collected.
  • For legal or security requirements: We may also transfer your personal data if required by law or if we believe in good faith that such a transfer is reasonably necessary to comply with legal processes, respond to claims, or preserve the security or rights of FLORIDA, its customers, or the public.
  • In the event of a merger, acquisition, or sale of all or part of FLORIDA by another company, or in the event of a sale or transfer of all or part of its business assets, the buyer will have access to certain information that may include personal data, in accordance with applicable legislation. Additionally, some of your personal data may be transferred during a restructuring, insolvency procedure, or any other similar situation, if permitted by applicable legislation and in accordance with it.

5. How long do we retain your personal data?

We will store your personal data in our databases while your account is active, for the duration of the contract signed with you, or, if necessary, for as long as needed to provide you with the services you request, to respond to your inquiries, or even to resolve issues or offer new and improved services. We may also retain your personal data according to our internal retention procedures, to the extent necessary to comply with our legal and regulatory obligations, to resolve disputes, and to enforce our contracts. However, once ten years have passed from the date of the recorded event, unless a specific legal provision stipulates otherwise, the data will be deleted from our databases. If retention is required beyond the specified period, the data will be dissociated from its owner.

Therefore, we may retain your personal data even after you stop using FLORIDA's services or our digital platforms, in accordance with the law.

 

6. How do we protect your personal data?

FLORIDA will adopt all necessary technical and organizational measures to protect the privacy and security of your personal data collected through our digital platforms. These measures include, among others: (i) storing your personal data in protected operating environments not accessible to the public, but only to authorized FLORIDA staff members, our agents, and contractors, and (ii) verifying the identity of registered users before they can access their personal data.


7. What are your rights?

a. You may access your personal data.
b. You may request the correction, updating, cancellation, or deletion of your personal data if it is inaccurate, incomplete, outdated, or was not collected with your authorization.
c. If your personal data has been processed with your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
d. You may request the deletion of your personal data when:
(i) Your personal data is no longer necessary for the purpose of processing;
(ii) You have withdrawn your consent for processing based solely on that consent;
(iii) You have objected to the processing of the data;
(iv) The processing of your personal data is unlawful;
(v) The personal data must be deleted to comply with a legal obligation applicable to FLORIDA. FLORIDA will take reasonable measures to inform other entities in the Group of such deletion.
e. You may request the restriction of processing:
(i) In the event of opposition to the accuracy of your personal data, to allow us to verify its accuracy;
(ii) If you wish to restrict your personal data rather than delete it in the event of unlawful processing;
(iii) If you want FLORIDA to retain your personal data because it is necessary for the defense of legal claims;
(iv) If you have objected to the processing, but FLORIDA carries out an investigation to determine if there are legitimate grounds for processing that override your rights.
f. You always have the option not to provide your personal data, in which case your activities and the functionalities we can provide may be limited.
g. You have the right to object to the processing of your personal data, including for marketing purposes based on profiling, or if the processing is based on FLORIDA’s legitimate interest.

 

8. How do we handle the personal data of children?

Our website is not intended for minors, as they do not have the legal age required to consume alcohol (“minors”), and therefore, we do not knowingly collect any personal data from minors. Users must be at least eighteen years old to create an account and participate in activities and transactions on our digital platforms. If we become aware or are informed that a minor has provided us with their personal data through our digital platforms, we will proceed with its deletion.
 

9. How can you contact us?

If you have any questions, complaints, or comments related to this privacy policy or our data collection practices, you can send us an email at: consultas@fifco.com.
 

Consent

By accepting this document, I acknowledge that I have been informed that Distribuidora La Florida S.A., with legal identification number 3-101-295868 (the "Company"), holds and manages a personal data database (the "Database") in which the information provided at this moment, as well as any other information provided during the commercial relationship I have or may have with the Company (the "Information"), is stored.
I understand that I have the right to request access, rectification, updating, and deletion of the Information as outlined in the "Personal Data Protection Law" and its regulations. I have also been informed that the Company and its affiliates are responsible for the Database, and I am aware of the address of their offices as indicated above.
I have been informed that I can exercise all the rights mentioned by expressing my desire via email to consultas@fifco.com. I also acknowledge that providing this information does not create any employment relationship with the Company or modify any current or potential employment relationship.