PRIVACY NOTICE

Costa Limited is a controller of your personal data. We respect your data and your privacy is important to us.

This Privacy Notice explains what personal data we collect and how it is used. This notice also explains what rights you have over your personal data and how you can use those rights.

You have the right to object to some of the processing which Costa carries out. More information about your rights and how to exercise these is set out in the “Your rights” section of this notice.

An overview of how we use your data is here

Costa Limited’s registered office is Whitbread Court Houghton Hall, Business Park Porz Avenue, Dunstable, Bedfordshire, LU5 5XE.

  1. Summary of how we use your data and your rights
  2. Information we collect from you
  3. Information we receive from third parties
  4. How we use information and the legal basis
  5. Data sharing
  6. International transfers
  7. Cookies and similar technologies
  8. Data retention
  9. Your rights
  10. Contact details
  11. Which Costa entity is the controller?

1. Summary of how we use your data and your rights

We use your data to provide and improve our products and services, including for marketing, research, feedback and enquiries, and for safety and security purposes. 

We will use your data to comply with laws and regulations. We may use your data to prevent and detect crime, such as fraud.  

You have the right to object to some of the processing Costa carries out. More information about your rights and how to exercise these is set out in the “Your rights” section of this notice. 

When you give consent, you are able to withdraw that consent at any time, for instance by emailing mycostadata@whitbread.com.  You can also email mycostadata@whitbread.com to exercise any other data rights, such as obtaining a copy of your data, correcting, deleting or restricting how we use your data.  Please see “Your rights” for more information.

You can unsubscribe from marketing communications at any time.  To opt out of marketing, including profiling for direct marketing purposes, you can either adjust the preference settings in your Costa Club account, or select “unsubscribe” in emails, or email costacoffeeclub@Whitbread.com

Our websites and app use cookies and similar technologies to improve functionality, recognise you and to customise your experience. You can reject and block cookies in your browser settings.  Please see our Cookie Notice for more information.

If you enable location services on the app, or you access the location finder on our sites and your browser settings allow this, your device will identify and alert you to the nearest Costa Store and Costa Express to your location. 

Costa is part of the Whitbread group of companies.  For details of the group see “Data sharing”. Data is shared within the Whitbread group when Whitbread Group plc provides support, advisory, IT, safety and security, including CCTV, and other services to Costa. 

2. Information we collect from you

We collect information when you purchase something or use our services.  This includes store visits, using our websites or app, joining our Costa Coffee Club, or corresponding with us. 

In particular:

  • We keep information you give us directly such as contact details (including name, email, address and telephone number), comments, date of birth, gender, region, frequency of visits, feedback, marketing opinions and competition entries.
  • We record and analyse store, web and app visits, details of your purchases and where you take advantage of our promotions.
  • When you sign up to in-store Wifi and give your Costa Coffee Club number to gain access we and the Wifi provider may check this number and keep a record of this.
  • If there is an incident, we may need to log information about it.
  • If you engage with us online via our websites or app our cookies and similar technologies will capture your IP address, your location, and record how you use the site or app to help improve it and improve your user experience, where your browser settings or permission allows for this.
  • If you post information online about us or provide feedback, we may keep a record.
  • If you contact us directly and complain or give feedback, receive compensation, or enter a competition, we will record details and all related information such as emails, letters and phone calls.
  • We use CCTV in our stores for the prevention and detection of crime and for safety and security reasons.

3. Information we receive from third parties

We may receive your information from other people.  This can happen when:

  • Someone buys you an E-Gift. They give your name and email address, so we can send you the E-Gift.
  • You participate in market research, such as focus groups or surveys.
  • We receive your Costa Coffee Club number from O2 to validate your Costa Coffee Club membership for unlimited in-store Wifi access.
  • Whitbread Group plc perform certain services, such as providing our CCTV system.

4. How we use information and the legal basis

We are allowed to use your data only if we have a proper reason to do so such as:

  • To fulfil a contract we have with you;
  • When it is in our legitimate interest;
  • When you consent to it; or
  • To comply with the law.

A legitimate interest is when we have a business or commercial reason to use your data. This involves us making an assessment of when we can rely on our legitimate interests. For more information on this assessment please contact privacyofficer@whitbread.com.

We have set out below how and why we may use your personal information and the legal basis we rely on. This is also where we tell you what our legitimate interests are.

When you buy something from us, join our Costa Coffee Club, or enter a competition we run, we use your information to fulfil our contract with you.

We take information to communicate with you, check your identity, take payment, and provide products and services, including awarding loyalty points if you are a Coffee Club member.

To run our business and pursue our legitimate interests, we use your information.

Our legitimate interests include keeping our records up to date, fulfilling our legal, compliance and contractual duties, working out which of our products and services may interest you, improving our site and apps, and services, developing new products and services, and telling you about them and conducting market research.

Further details of our legitimate interests:

To run and promote our business, we use your information:

  • To provide and improve our products and services, including in-store Wifi, Costa Coffee Club, and Costa E-Gift, and to respond to you if you contact us.
  • To record call centre communications, including incoming and outgoing calls and emails, for staff training, quality improvement purposes and establishing facts.
  • When we monitor Costa websites, social media platforms such as Facebook and Twitter and online services including our mobile app and responses to email marketing. If you post comments online or in other media we may capture this information, contact you, and use it to improve our products and services.
  • To run competitions and promotions and track which offers seem of interest to you.
  • To understand you better as a customer by analysing your transactions and other information you provide to us or which we learn through your interactions with us.
  • To send you emails including offers tailored to your perceived preferences where you are a Costa Coffee Club member and your preference settings permit this. We record which emails seem to be of interest to you.  Based on your purchase history and membership card usage, some Costa Coffee Club members may be offered additional loyalty points.
  • To contact you where you provide us with market research feedback or pass this data to a third-party business partner of ours for panel market research analysis.

To prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, including where we are required to do so by law we may:

  • Monitor Costa Coffee Club accounts and review CCTV, record call centre communications and emails.
  • Use other organisations to check the validity of the credit or debit card details you use to pay (for further details see “Data sharing” below).

To comply with law, assess and uphold legal or contractual rights and claims, and for monitoring, auditing and training on compliance matters:

  • We keep records and pass your data to Whitbread Group plc and our insurers when necessary (for further details see Data sharing below).
  • We monitor, and record call centre communications, including incoming and outgoing calls and emails.
  • We may verify your identity.
  • We keep records to comply with health and safety legislation, including accounting for the number of individuals on our premises and logging accidents.

We may, if you give us consent

  • Send you electronic marketing, including promotions and offers, in relation to our products and services if you are a member of our Costa Coffee Club and inform you of other outlets that award Costa Coffee Club points. Costa Coffee Club members can subscribe or unsubscribe from our marketing communications at any time.  For instance, preferences can be adjusted in account settings online.
  • Use cookies or similar technologies on the website, app and in marketing emails, including analytic cookies.  For more details on our use of such technologies, click here to see our Cookie Notice.
  • Through the settings on your device, send you push notifications through the app.
  • If you use the store locator in the app or site and enable location services it will notify you of the nearest Costa or Costa Express.
  • Use data for other purposes where we explain that purpose when we ask for your consent.

When you give consent, you are able to withdraw that consent at any time by contacting us, for instance by emailing mycostadata@whitbread.com.  If you do so we can only continue to use your data if another legal basis applies, such as when we’re required to do something by law.

Nevertheless, you have an absolute right to opt-out of direct marketing, including profiling for direct marketing purposes, at any time.  You can opt out of marketing by selecting “unsubscribe” in emails or by adjusting the preference settings on your Costa Coffee Club account or by emailing costacoffeclub@Whitbread.com.

When the law requires us to process your data we will do so.  This can include

  • Legal, compliance, regulatory and investigative purposes, including for government agencies and law enforcement.
  • When you exercise your rights under data protection legislation, including when you ask to subscribe or unsubscribe from our marketing communications.

5. Data sharing

Costa Limited is part of the Whitbread group of companies. Details of the Whitbread group can be found on our corporate website at www.whitbread.co.uk.   The group includes Whitbread Group plc and Costa Express Limited.

Costa Limited shares data within the Whitbread group when Whitbread Group plc provide us with support, advisory, IT, safety and security, including CCTV, and other services.

For some activities Costa uses third party service providers, for instance O2 provide Wifi in our stores.  When these service providers ask for customer data from you we may share information with them, such as whether a correct Costa Coffee Club member number has been entered to access Wifi.

We use third party providers for the following services:

  • Wifi (O2)
  • Sending promotional offers
  • Customer feedback surveys
  • Gift cards (including E-Gifts)
  • Loyalty scheme platform
  • Insurance
  • IT development, support, maintenance and hosting, including the provision of applications and website hosting
  • Payments’ processing to enable you to pay by credit or debit card
  • CCTV system provision and maintenance

If our business is to be integrated with another business or sold, your details would be shared with our advisers and any prospective purchaser’s advisers.  Your information will be passed to the new owners and you would be notified.

Personal data may be shared with government authorities and/or law enforcement officials for the prevention or detection of crime, if required by law or if required for a legal or contractual claim.

6. International transfers

Sometimes we may need to send or store your data outside of the European Economic Area (the EU plus Iceland, Lichtenstein and Norway) (‘EEA’).  For example, to follow your instructions, comply with a legal duty or to work with or receive services from our service providers who we use to help run your accounts and our services.

If we do transfer information outside of the EEA, we will make sure that it is protected by using one of these safeguards:

  • Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. Some countries have been deemed adequate by the EU.
  • Put in place a contract with the recipient that means they must protect it to the same standards as the EEA or use other mechanisms and measures to achieve adequate protection. We also may use the Standard Contractual Clauses published by the EU.
  • Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA.
  • Binding corporate rules. These are internal rules adopted by group companies to allow international transfers of personal data to entities within the same corporate group located in countries which do not provide an adequate level of protection.

For our service provider in the US, who helps us with our customer feedback surveys, we rely on Privacy Shield.  For our service provider in India, who has restricted access to some data to provide us with IT support and maintenance services, we rely on contractual measures.  For further details on the mechanisms used please contact privacyofficer@whitbread.com.

7. Cookies and similar technologies

Our website, apps and marketing emails use cookies and similar technology. Full information is in our Cookie Notice. This includes information on how to adjust your browser settings to accept or reject cookies.

8. Data retention

We keep your data to enable us to fulfil our contract with you or to provide services, whilst you are an active user of our site, app or Costa Coffee Club, where required by law or to protect legal rights.

We always look to keep your data for the minimum time in line with data protection principles and our processes.  For example, we keep:

  • Information on Costa Coffee Club members.
  • Records of payment information in line with tax law and audit requirements.
  • Customer feedback and correspondence with our customer services teams for up to 4 years afterwards, depending on the nature of the interaction and any applicable law, such as health and safety.  This enables us to respond to any questions or complaints.
  • Information to maintain records according to rules that apply to us.

If you unsubscribe from marketing communications we keep a record of this request indefinitely to ensure we do not send you direct marketing again.

We may keep your data for longer if we cannot delete it for legal, regulatory or technical reasons.

9. Your rights

You have rights over your personal data.

You can:

  • ask for a copy of your information;
  • ask for information to be corrected;
  • ask for information to be erased or deleted;
  • ask for us to limit or restrict processing;
  • object to us processing your data, in particular where we use the data for direct marketing, including profiling for direct marketing purposes.  The right to object does not apply if we must process the data to meet a contractual or legal requirement;
  • ask us to send you a copy in a structured digital format or ask for us to send it to another party.

Some rights, however, may be limited. We may be obliged by law or regulation to keep information.  We must respect other people’s privacy as well, which means we may need to redact or remove information where it includes personal data about someone else, even if it is connected to your data.  On occasion there may be a compelling legitimate interest to keep processing data.

If you want a copy of your data, to object to how we use your data, or ask us to delete it or restrict how we use it or, please see ‘Contact details’ below.  To process a request from you, we may need to confirm your identity to ensure we’re accessing the right data.

You have a right to complain to an EU data protection authority.  This can be where you live, work or where the matter occurred. In the UK, the authority is the Information Commissioner’s Office (the “ICO”).

10. Contact details

To exercise any of your rights or to withdraw consent you can email: mycostadata@whitbread.com.

To discuss or change your Costa Coffee Club account details, including preference settings, you can log into ‘My Account’ and go to (account details) and Contact Preferences or contact customer services at costacoffeclub@Whitbread.com.

For any queries relating to data protection please contact privacyofficer@whitbread.com or by writing to them at Privacy Officer, Porz Avenue, Whitbread Court, Dunstable, Beds LU5 5XE.

If we make any changes or updates to this notice we will communicate these.

11. Which Costa entity is the controller?

The controller for your information is Costa Limited, Whitbread Court Houghton Hall, Business Park Porz Avenue, Dunstable, Bedfordshire, LU5 5XE. Costa Limited runs the Costa Coffee Club within Great Britain.

Some stores using the Costa brand are franchisees.  Franchisees are all committed to protecting your privacy but, just to be clear, each Costa franchisee is an independent business and is responsible for the operation of its own stores and compliance with data protection laws.