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STARBUCKS PRIVACY NOTICE

At Starbucks, we approach data and privacy as we approach everything we do: we
put people first.

As part of our effort to protect your privacy and to comply with applicable
privacy and data protection laws, we strive to consider all of our data
governance practices through the lens of the recognized principles of data
minimization, limited collection, and limited use, among other key areas
addressed below. We do so to respect and maintain your trust. In other words, we
believe that taking care of you includes taking care of your data and privacy.
Grab a cup of coffee and learn more below.

Starbucks Privacy Notice

Last Revised: October 6, 2023

Overview

This Starbucks Privacy Notice describes the types of personal information that
Starbucks Corporation and its respective subsidiaries and affiliated companies
(“Starbucks,” “we,” and “us”) collect, how we use it, how and when it may be
shared, and the rights and choices you have with respect to your information. It
also explains how we communicate with you and how you can make requests or
submit inquiries to us about your information. Our goal is to help you
understand how we use your information to improve our products, services,
marketing, and interactions with you, as part of our commitment to maintaining
your trust. Thank you for taking the time to read and understand our data and
privacy related practices.

By continuing to use Starbucks Services you acknowledge this Privacy Notice and
agree to our Terms of Use and other important policies, all available on our
Online Policies page.

Contents

You may skip to the specific sections of our Privacy Notice by selecting any of
the sections listed below.

 1.  Applicability and Scope
 2.  Updates to this Privacy Notice
 3.  Information We Collect
 4.  Sources of Information
 5.  How We Use Your Information
 6.  How We Disclose Your Information
 7.  Cookies, Web Beacons, and Similar Technologies
 8.  How We Protect Your Information
 9.  Retention
 10. Children’s Privacy
 11. Starbucks WiFi
 12. Your Choices & Rights
 13. Notice of Financial Incentive & Starbucks® Rewards
 14. Additional Disclosures for Data Subjects in the EEA, the U.K. and
     Switzerland
 15. Participation in the Privacy Framework
 16. Contact Us

1. Applicability and Scope

This Privacy Notice (“Notice”) applies to the websites located at starbucks.com,
starbucksreserve.com, princi.com, starbucks.ca, the Starbucks mobile
applications available at https://www.starbucks.com/coffeehouse/mobile-apps
(“Starbucks App”), when you visit our stores, and through any other websites or
applications owned and operated by Starbucks brands or products that direct the
viewer or user to this Notice (“Starbucks Services”). Our websites and mobile
applications may offer links to websites and/or other mobile applications that
are operated by third parties and not by Starbucks. If you visit one of these
linked websites, you should read the website’s privacy notice, terms and
conditions, and their other policies. We are not responsible for the policies
and practices of third parties. Any information you give to those organizations
is governed under their privacy notice, terms and conditions, and other
policies.

2. Updates to this Privacy Notice

We may update this Notice from time to time. We will notify you of material
changes to this Notice and will update the Last Revised date on this Notice. We
encourage you to look for updates and changes to this Notice when you access our
websites and mobile applications.

3. Information We Collect

When you visit and use the Starbucks Services, we may collect the following
categories of information:

 * Identifiers – We may collect information that can be used to identify you,
   such as your first and last name, phone number, your address book, username
   and password, email address, postal address, IP address, day and month of
   your birthday, and demographic information (such as gender).
 * Financial Information – We may also collect information such as your credit
   card and debit card information, telephone number, and name.
 * Commercial Information – We may collect information about your transactions
   in our stores, on our websites or via our Starbucks App 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.
 * Electronic Network Activity Information – We may collect information related
   to your electronic network activity, such as your browsing history,
   information about how you use the Starbucks Services, information about your
   device, and information related to Starbucks website’s “live help” chat
   feature.
 * Geolocation Information – We may collect information about your location of
   your device, such as information derived from your device (e.g., based on a
   browser or device’s IP address).  We may also use location-based technology
   in our retail locations, to collect information about the presence of your
   device, if your Bluetooth is turned on and your device settings allow for
   this.
 * Audio and Visual Information – We may collect audio and visual information
   when you use the Starbucks Services.  For example, closed circuit video
   surveillance cameras (“CCTV”) may be installed at some of our retail
   locations to monitor building security and assist in crime prevention,
   detection, and investigation, and to ensure the safety of our staff and
   visitors to our facilities, and these CCTV cameras may collect audio, visual,
   and similar information.  Also, depending on your choices, we may collect
   audio information when you use voice ordering.
 * Inferences – We may also collect inferences drawn from the other information
   described above.

Additionally, depending on how you use the Starbucks Services, we may collect
the following categories of sensitive personal information from you:

 * Precise Geolocation Information – We may collect information about the
   precise location of your device (e.g., GPS latitude and longitude),
   consistent with your device settings. We may also use location-based
   technology in our retail locations, to collect information about the presence
   of your device, if your Bluetooth is turned on and your device settings allow
   for this. We may collect this location information or derive it from your
   GPS, WiFi, Bluetooth or other location-based technology for purposes of
   facilitating our services, such as to provide you with information about
   stores near you, to enable you to remotely order and pay for our products and
   services, or so that you may have certain Starbucks products delivered to you
   by a third-party vendor.

We may aggregate or de-identify the information described above.  Aggregated or
de-identified data that we do not attempt to reidentify is not subject to this
Notice.

Without this information, we may not be able to provide you with all the
requested services.

4. Sources of Information

In addition to the information we receive from you, we may also receive the
categories of information described above from other sources including from
other users of Starbucks Services (such as when they purchase a gift for you),
advertising partners, co-sponsors, internet service providers, data analytics
providers, operating systems and platforms, social networks, and publicly
available sources.  For example, if you access any social media or similar
services through the Starbucks Services to login or to share information about
your experience on our Starbucks Services with others, we may collect
information from these third-party services.

5. How We Use Your Information

We may use your information for business 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 may use the information we
collect about you to:

(a)  To Provide Our Services – We may process your information when you access
or use the Starbucks Services, including to:

 * process or fulfill orders and transactions;
 * maintain and service accounts;
 * support and improve our loyalty programs, such as Starbucks® Rewards;
 * deliver gift cards or e-gifts, and any associated personalized messages, in
   accordance with your instructions;
 * debug to identify and repair errors that impair existing functionality;
 * facilitate the functionality of our websites and mobile applications;
 * process payments; and
 * customize experiences and personalization when you are in and around our
   stores, if you have given permission for location sharing.

(b)  To Communicate With You – We may process certain information in order to
communicate with you in relation to your accounts, our services, our marketing,
and your requests, including to:

 * provide customer service, including when you interact with our customer
   service agents through our website’s “live help” chat feature, and requests
   for information;
 * communicate with you about orders, purchases, returns, services, accounts,
   programs, contests, and sweepstakes;
 * 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
   Starbucks 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.

(c)  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 may process certain personal information, including to:

 * maintain, improve, and analyze our websites, mobile applications, ads, and
   the products and services we offer; and
 * help to ensure security and integrity of the Starbucks Services, including to
   detect, prevent, or investigate suspicious activity or fraud.

(d)  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 may use your personal information to ensure our terms,
policies, and agreements with you and any third parties are enforced.

(e)  To Comply with Applicable Laws – We may be required to process certain
information under certain laws and regulations, such as tax laws, as well as to:

 * maintain appropriate records for internal administrative purposes; and
 * comply with applicable legal and regulatory obligations, and respond to
   lawful governmental requests, as needed.

(f)  Targeted Advertising – We may process your information to provide you with
targeted advertising (also known as cross-contextual advertising and online
behavioral advertising) and offers and promotions that you may be interested in.

(g)  With Your Consent – We may process certain information in order to fulfill
any other business or commercial purposes at your direction or with your
consent.

6. How We Disclose Your Information

We may disclose your information as needed to fulfill the purposes described in
this Notice and as permitted by applicable law.

 (a) When We Work Together – We may share information between and among
Starbucks Corporation, its subsidiaries, and affiliated companies for purposes
of management and analysis, decision making, and other business purposes. For
example, we may share your information with our subsidiaries and affiliated
companies to administer our loyalty programs, process orders and requests, and
expand and promote our product and service offerings.

(b)  When We Work with Service Providers & Business Partners – We may share
identifiers, commercial information, electronic and network activity,
geolocation and precise geolocation information, audio and visual information,
and inferences, as described above, for a variety of business purposes, such as
payment processing, website and data hosting, location mapping, product and
service delivery, customer service, advertising and marketing (including
counting ad impressions, ensuring compliance with industry standards,
personalization, analytics services, security and performance monitoring,
maintaining and servicing accounts, processing or fulfilling orders and
transactions, verifying customer information, research, auditing, and data
processing. We strive to contractually prohibit these service providers and
business partners from retaining, using, or disclosing your confidential
personal information for any purpose other than performing agreed upon services
for us.

(c)  When We Work on Business Transactions – If we become involved with a
merger, corporate transaction 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.

(d)  When Sharing Helps Us Protect Safety and 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,
safety of Starbucks or our customers or partners.

(e)  When You Give Consent – We may share information about you with other
companies if you give us permission or direct us to share the information.

(f)  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.  We are not responsible for the information you choose
to submit in these public areas.

7. Cookies, Web Beacons and Similar Technologies

We and others may use a variety of technologies to collect information about
your device and use of our websites and mobile applications. These technologies
include first- and third-party cookies, web beacons, JavaScript, entity tags,
and HTML local storage. Most web browsers can be programmed to accept or reject
the use of some or all of these technologies, although you must take additional
steps to disable or control other technologies. For more information on
exercising your preferences in relation to cookies and similar technologies,
please see the section of this Notice titled “Your Choices & Rights”.

 * 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 (“persistent cookies”).
   Cookies contain information that can later be read by a web server.

You may be able to reject cookies, web beacons, entity tags and HTML5 local
storage by adjusting the appropriate settings in your browser. Each browser is
different, but many browsers have preferences or options that may be adjusted to
allow you to either 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 review the instructions provided by the following browsers: Internet
Explorer, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile; and
Android browser.

 * Interest-Based Ads – Many advertising companies that collect information for
   interest-based advertising are members of the Digital Advertising Alliance
   (DAA) or the Network Advertising Initiative (NAI), both of which maintain
   websites where people can opt out of interest-based advertising from their
   members. To opt-out of website interest-based advertising provided by each
   organization’s respective participating companies, visit the DAA’s opt-out
   portal available at http://optout.aboutads.info/, the DAA of Canada’s opt-out
   portal available at https://youradchoices.ca/en/tools, or visit the NAI’s
   opt-out portal available at http://optout.networkadvertising.org/?c=1.

Residents of the European Union may opt-out of online behavioral advertising
served by the European Interactive Digital Advertising Alliance’s participating
member organizations by visiting https://www.youronlinechoices.eu/.

To opt-out of data collection for interest-based advertising across mobile
applications by participating companies, download the DAA’s App Choices mobile
application opt-out offering at https://youradchoices.com/appchoices.

 * Adobe Flash Player Technology – We allow Adobe to set and enable special
   cookies that are necessary to deliver video content for Adobe Flash Player.
   You cannot remove Flash cookies simply by changing your browser settings. If
   you would like to limit the websites that can store information in Flash
   cookies on your device, you must visit the Adobe website:
   http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

 * Web Beacons – Web beacons are small, transparent images that are embedded in
   web pages, applications, and emails that are sometimes called “clear gifs,”
   “single pixel gifs”, “page tags” or “web bugs.” We use web beacons to track
   the web pages you visit, to test the effectiveness of our marketing, and to
   find out if an email has been opened and acted on.
 * JavaScript – JavaScript are code snippets embedded in various parts of
   websites and applications that facilitate a variety of operations including
   accelerating the refresh speed of certain functionality or monitoring usage
   of various online components.
 * Entity Tags -- Entity Tags are HTTP code mechanisms that allow portions of
   websites to be stored or “cached” within your browser and validates these
   caches when the website is opened, accelerating website performance since the
   web server does not need to send a full response if the content has not
   changed.
 * HTML5 Local Storage – HTML5 local storage allows data from websites to be
   stored or “cached” within your browser to store and retrieve data in HTML5
   pages when the website is revisited. 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 websites or mobile applications and the various
   services and functionality we offer. Without these technologies, some of the
   services and functionality on our websites and mobile applications would not
   work properly.
 * Performance Monitoring – Some of these technologies help us analyze and
   estimate traffic and assess the volume of use of services and functionality
   on websites and mobile applications. They show us how visitors and customers
   interact with our digital properties, 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 directly identifiable
   information (e.g., your name, email address or phone number) is collected.
 * User Convenience – Some of these technologies enhance the ease of use of our
   websites and mobile applications 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 websites or when you last used
   a website or mobile application service or functionality.
 * Marketing – Some of these technologies are used to tailor your experience on
   our website, within our mobile applications, or across your applications or
   devices by controlling the promotions, advertisements and other marketing
   messages that may appear when you access or use these or other digital
   properties.

Taken together, these technologies help us learn which services and
functionality you are using and how you are accessing information about us. We
may use this information to personalize your visit to a website or use of a
mobile application or to send you relevant promotions and advertisements.

8. How We Protect Your Information

Starbucks uses reasonable technical, physical, and administrative security
measures to reduce the risk of loss, misuse, unauthorized access, disclosure or
modification of your information. However, no security system is perfect, and
due to the inherent nature of the Internet, we cannot guarantee that data,
including personal information, is absolutely safe from intrusion or other
unauthorized access by others. You are responsible for protecting your
password(s) and maintaining the security of your devices.

9. Retention

Starbucks stores information as reasonably necessary and proportionate to
accomplish the purposes identified in this Notice based on criteria such as the
length of time we need to provide the services to you, and to meet legal
requirements, including record retention, resolving disputes, and enforcing our
agreements. Our retention of your information is governed by applicable law. 

The personal information that you provide us is stored and processed on servers
owned by Starbucks and other companies in the United States, Canada or elsewhere
around the world, including locations outside of the country or jurisdiction
where you are located. Regardless of the company or person who processes your
information and where it is processed, we will take steps to transfer and
protect your information through appropriate safeguards in accordance with
applicable data protection laws and this Notice.

10. Children’s Privacy

We do not intend for our websites or online services to be used by anyone under
the age of 13. We do not knowingly collect, sell, or share information of
consumers between the ages of 13 – 16.  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 Notice. For more
information, please see our Terms of Use. 

11. Starbucks Wi-Fi

Many Starbucks stores support providing you access to wireless internet (WiFi)
at no charge. For any such WiFi access, please carefully review the terms of use
listed on the activation page prior to accepting and connecting.

12. Your Choices & Rights, including State-Specific Rights  

(a)  Your Choices

 * Location Services – In order to use certain Starbucks Services, such as
   mobile order and pay (“MOP”) and location-based services and technology, you
   must either (a) enable “location services” in the Starbucks App; and/or (b)
   set the permissions in your mobile device to allow communication of this
   information.

If you allow for location sharing, your device may communicate with us in ways
that allow for us to customize your experience in and around Starbucks stores,
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. Precise geolocation may be used to fulfill
services and application functionality you choose to engage with. You can manage
the use of that personal information at any time in your device settings.

For most mobile devices, you can disable the collection of geolocation
information by turning off location services on your device.  If you have any
questions about how to prevent Starbucks from collecting your geolocation, we
recommend you contact your mobile device service provider or the device
manufacturer. Certain Starbucks App features and some Starbucks Services may not
work properly without information about your location. You can re-enable the
collection of geolocation information, at any time, by turning on location
services on your device.

 * Voice Ordering – In order to use certain Starbucks Services,  such as voice
   ordering, when available, you must (a) enable “microphone” and “speech
   recognition” in the Starbucks App; and/or (b) set the permissions in your
   mobile device to allow communication of this information.
 * Email Communications, Push Notifications, and In-App Messages – The Starbucks
   App allows all users to set preferences for receiving promotional email
   communications from Starbucks, receiving push notifications on your device,
   and receiving inbox messages. Please note as well that you may opt-out of
   receiving email communications at any time by adjusting your Starbucks online
   account settings or by clicking the “unsubscribe” link included within any
   commercial email we send you.

If you use the Starbucks App features described above, you consent to the
transmission of your user information to Starbucks and/or its agents, and
authorize Starbucks and/or its agents, to record, process, and store such user
information as necessary for administering the Starbucks App features and for
purposes described in this Notice.

(b)  Your Rights, including State-Specific Rights

Depending on where you live (including California, Colorado, Connecticut, Utah,
and Virginia), you may be entitled to certain rights with respect to your
personal information, as described below.

 * Right to Know – You may have the right to know what personal information the
   business has collected about you, including the categories of personal
   information, the categories of sources from which it is collected, the
   business or commercial purposes for collecting, selling, or sharing it, and
   the categories of third parties to whom we disclose it.
 * Access and Data Portability – Subject to certain exceptions, you may have the
   right to request a copy of the personal information that we collected about
   you during the 12 months before your request.
 * Deletion – You may have the right to request that we delete information that
   we collected from you and retained, subject to certain exceptions.
 * Correct Inaccurate Information – You may have the right to request that we
   correct inaccuracies in the personal information we maintain about you.  You
   may also correct information about you for Starbucks Rewards in the Starbucks
   App.
 * Targeted Advertising – We do not sell your information for monetary or
   valuable consideration.  You may have the right to opt-out of having your
   personal information shared for purposes of targeted advertising.  To
   opt-out, click this “Do Not Share My Personal Information” link.
 * Sensitive Information – Companies who collect, use, and disclose your
   sensitive personal information for purposes other than to provide you with
   goods or services are required to provide you with the right to limit the use
   and disclosure of your sensitive personal information by providing a “Limit
   the Use and Disclosure of My Sensitive Personal Information” link. Starbucks
   only collects, uses, and discloses your sensitive personal information to
   provide services to you, therefore Starbucks is not required to provide this
   link.
 * Opt-Out Preference Signals – Some web browsers allow customers to
   automatically exercise their right to opt-out of sale/sharing with all
   businesses they interact with online by initiating an opt-out preference
   signal. We will honor such opt-out preference signals.
 * Appeals – You may appeal our decision with respect to a request you have
   submitted by contacting us as described in the “Contact Us” section below.

Requests for U.S. residents should be submitted through this form HERE.

Request for Canadian residents should be submitted through this form HERE.

U.S. and Canadian residents may also submit request by calling 1-800-STARBUC
(782-7282).  Once we receive your request, we may verify it by requesting
information sufficient to confirm your identity.  You may be entitled to submit
a request through an authorized agent or to appeal a refusal to take action on
your request.  To designate an authorized agent to exercise your rights, we will
require written proof that the authorized agent has been authorized to act on
your behalf or a copy of the power-of-attorney document granting that right.

If you are an authorized agent or you are submitting a request on behalf a
customer, please submit your request through this form HERE or via email to
privacy@starbucks.com.

(c)  Other California Rights

 * If you are a California resident, you can request a notice disclosing the
   categories of personal information we have shared with third parties for the
   third parties’ direct marketing purposes. To request a notice, please submit
   your request by postal mail to: Starbucks, P.O. Box 20430, Augusta, GA 30916
 * Some 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, as there is no standard for how online
   services should respond to such signals. As standards develop, we may develop
   policies for responding to do-not-track signals that we will describe in this
   Notice.

(d)  Privacy Metrics

Privacy Rights Metrics (January 2022 – December 2022) – Includes requests from
the United States and Canada:

Right to Know
•  Requests Received – 654
•  Requests Complete – 353
•  Requests unable to be completed* – 301
•  Average completion time – 9 days


Right to Delete
•  Requests Received – 1771
•  Requests Complete – 936
•  Requests unable to be completed* – 835
•  Average completion time – 12 days


*Requests may be unable to be completed due to factors such as inability to
verify the customer, duplicate requests, or no information is found.

13.  Notice of Financial Incentive & Starbucks® Rewards

Starbucks® Rewards is one way in which Starbucks endeavors to reward and thank
loyal customers for patronizing our business and purchasing Starbucks products. 
Starbucks® Rewards members opt in by signing up for Rewards online or through
the Starbucks App and are able to earn and accumulate "Stars" that can be
redeemed for Starbucks® Rewards benefits at participating Starbucks stores. If
you would like to become a Starbucks® Rewards member, please see the Starbucks
Rewards Terms of Use available at https://www.starbucks.com/rewards/terms.

Starbucks collects and uses the categories of personal information described in
the “Information We Collect” section, including information you voluntarily
provide us (such as your name and email), information we collect automatically,
and information from other sources to operate the Starbucks® Rewards loyalty
program, including to send you promotions, content, and special offers and the
other uses described in this Notice.  We work with many service providers and
business partners to offer the benefits of our Starbucks® Rewards loyalty
program.  Those partners may fall into the following categories: delivery
partners, Starbucks global licensees, subsidiaries, and affiliated companies,
and our service providers and business partners.  You can learn about the
business partners with whom we share your information by referring to the “How
We Disclose Your Information” section.  Starbucks does not assign monetary value
for the information we collect through the Starbucks® Rewards loyalty program
when sending email communications.  You may opt out of receiving commercial
email communications at any time by adjusting your Starbucks online account
settings, or by clicking the “unsubscribe” link included within any commercial
email we send you. Participation in Starbucks® Rewards is voluntary, and you may
withdraw from the Starbucks® Rewards loyalty program by visiting the Account
section in the Starbucks App, by requesting deletion of your information by
filling out this form HERE, or by calling Starbucks customer service. Please
note that by withdrawing from Starbucks® Rewards, you will no longer have access
to your Starbucks® Rewards account, but you can otherwise continue to use the
Starbucks app. All points and rewards you have earned until the time of
withdrawal will no longer be available.  As previously shared, to communicate
and provide services to you through the Starbucks® Rewards loyalty program, we
need to use your personal information. Therefore, if you choose to delete your
personal information from the Starbucks® Rewards loyalty program, we can no
longer provide you with services through this loyalty program. 

Based on our reasonable and good faith estimate, we receive value from
Starbucks® Rewards in increased customer loyalty and patronage, though any value
will vary by Starbucks® Rewards member depending on purchases made, which offers
a member takes advantage of, and many other factors.

14. Additional Disclosures for Data Subjects in the EEA, the U.K., and
Switzerland

This section provides general information about how Starbucks collects, stores,
uses, transfers and otherwise processes personal data in or from certain
countries in the European Economic Area, the United Kingdom, and Switzerland
(together, for purposes of this section of this Notice, “EEA”), in accordance
with the General Data Protection Regulation (GDPR) and its local
implementations. This section does not supersede the applicability of any
privacy policy found on the website of an EEA-based Starbucks affiliate with
whom you have engaged, as that entity would be the data controller with respect
to your personal data and the entity to which your data subject rights requests
should be directed.

(a)  Lawful Bases of Processing – Where a Starbucks entity is acting as a data
controller that determines the purposes and means of processing your personal
data, such as when we collect, use, and share personal data as described in this
Notice, we must have a lawful basis for processing for doing so. Our lawful
bases for processing personal data include:

 * to conclude or perform a contract with you, for example to:
   * process your purchases of or requests for products and services, including
     delivering
   * gift cards in accordance with your instructions;
   * communicate with you about orders, purchases, returns, services, accounts,
     programs,
   * contests, and sweepstakes;
 * for our legitimate business purposes, including to:
   * respond to your customer service inquiries and requests for information;
   * maintain, improve, and analyze our websites, mobile applications, ads, and
     the
   * products and services we offer;
   * detect, prevent, or investigate security breaches or fraud; and
   * facilitate the functionality of our websites and mobile applications;
 * to comply with our legal obligations, for example to maintain appropriate
   records for internal administrative purposes and as required by applicable
   law, and provide important product safety information and notice of product
   recalls; and
 * on the basis of your consent, for example to send you via email and other
   electronic means personalized promotions and special offers or informing 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.

(b)  Your EEA Data Subject Rights – Under certain circumstances, by law you have
the right to:

 * Request access to your personal information (commonly known as a “data
   subject access request”). This enables you to receive a copy of the personal
   information we hold about you.
 * Request correction of the personal information that we hold about you.
 * Request erasure of your personal information. This enables you to ask us to
   delete or remove personal information where there is no good reason for us
   continuing to process it.
 * Object to processing of your personal information where we are relying on a
   legitimate interest (or those of a third party), or where we are processing
   your personal information for direct marketing purposes.
 * Request the restriction of processing of your personal information. This
   enables you to ask us to suspend the processing of personal information about
   you.
 * Request the transfer of your personal information to another party, when
   possible.
 * Not be subject to automated decision-making producing legal or significant
   effects on an individual, which we do not engage in.

To exercise any of these rights, please see the “Your Choices & Rights” section,
or contact us as set forth in the “Contact Us” section below and specify which
GDPR privacy right(s) you wish to exercise. We must verify your identity in
order to honor your request, which we will respond to within 30 days of receipt.

(c)  Retention – As described in the “Retention” section, as a general rule, we
keep your 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 data for
longer than our specified retention periods to honor your requests, including to
continue keeping you opted out of marketing emails, or to comply with legal,
regulatory, accounting or other obligations.

(d)  Transfers Outside the EEA – Your personal information may be transferred
to, stored, and processed in a country other than the one in which it was
collected, including the United States.  It may also be processed by staff
operating outside the EEA who work for 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 GDPR and as
described in this Notice.

(e)  Complaints – If you have any issues with our compliance, you have the right
to lodge a complaint with an EEA supervisory authority (link). We would,
however, appreciate the opportunity to first address your concerns and would
welcome you directing an inquiry first to us per the “Contact Us” section below,
or to our U.S.-based third-party dispute resolution provider (free of charge) at
https://feedback-form.truste.com/watchdog/request You may also contact our Data
Protection Officer (“DPO”) at any time at privacy@starbucks.com.

15. Participation in the Data Privacy Framework

Starbucks participates in the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the
UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework
(Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Starbucks
complies with the U.S. Department of Commerce requirements regarding the EU-U.S.
Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the
processing of personal data received from the European Union in reliance on the
EU-U.S. DPF, and from the United Kingdom (and Gibraltar) under the UK Extension
to the EU-U.S. DPF. Starbucks complies with the U.S. Department of Commerce
requirements regarding the Swiss-U.S. Data Privacy Framework Principles
(Swiss-U.S. DPF Principles) with regard to the processing of personal data
received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any
conflict between the terms in this Privacy Notice and the EU-U.S. DPF Principles
and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more
about the Data Privacy Framework (DPF) program, and to view our certification,
please visit https://www.dataprivacyframework.gov/.

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 Data Privacy Framework.

Starbucks complies with the Data Privacy Principles for all onward transfers of
personal data from the EU, the U.K., and Switzerland, including the onward
transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy
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.

For complaints regarding DPF compliance not resolved by any of the other DPF
mechanisms, you have the possibility, under certain conditions, to invoke
binding arbitration. Further information can be found on the official DPF
website https://www.dataprivacyframework.gov/.

16. Contact Us

We welcome your questions, comments and concerns about privacy. You can contact
Starbucks Customer Service online at http://customerservice.starbucks.com (by
phone at 800- (782-7282), or by postal mail at: Starbucks Customer Service,
Starbucks, P.O. Box 549, Fort Smith, AR 72902.

You may reach our Global Privacy Department and our Data Protection Officer at
privacy@starbucks.com.

Additional contact information may be found below for various Starbucks
entities.

 * Country – Canada
   * Entity Name – Starbucks Corporation (Canada)
   * Entity Address – P.O. Box 20430, Augusta, GA 30916 USA
   * Additional Contact (If Any) –
     * Customer Service
       * 800-Starbuc (782-7282)
       * tel.: 800-Starbuc (782-7282)
 * Country – France
   * Entity Name – Starbucks Coffee France SAS
   * Entity Address – 38 rue des Jeûneurs, 75002 Paris
   * Additional Contact (If Any) –
     * Customer Support
       * service.clientele@starbucks.fr
       * : +33 01 44 76 72 00
 * Country – Germany
   * Entity Name – AmRest Coffee Deutschland Sp. Z oo & Co. KG
   * Entity Address – Dachauser Strasse 6, 80335, Munich
   * Additional Contact (If Any) –
     * Customer Relations
       * Starbucks.Gaesteservice@amrest.eu
       * : +49 (0) 89.551.555.990
 * Country – U.K.
   * Entity Name – Starbucks Coffee Company (UK) Limited
   * Entity Address – Building 4 Chiswick Park, 566 Chiswick High Road, London,
     W4 5YE
   * Additional Contact (If Any) –
     * Customer Support
       * Please contact our Customer Care team here.
       * : +443330050449 or +442088345050 (app)
 * Country – U.S.
   * Entity Name – Starbucks Reserve; Princi
   * Entity Address – Starbucks, P.O. Box 20430, Augusta, GA 30916
   * Additional Contact (If Any) –
   * Customer Service
     * http://customerservice.starbucks.com
     * : 800-Starbuc (782-7282)




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