| Document Title | Website Privacy Policy |
|---|---|
| Version / Status | v1.0 (Final) |
| Effective Date | 15 July 2026 |
| Next Review Date | July 2027 |
| Document Owner | Legal Director Europe |
Welcome to the Tropicana Brands Group website for the United Kingdom (UK). Below you will find our privacy policy which details how we collect and handle your personal data.
It is our aim through this privacy policy (“Policy”) to explain what personal data we collect about you and why we collect it. We also want to make sure you understand how we use and share your personal data and the choices available to you regarding such use. Our goal is to earn and keep your trust as you visit websites and applications about our products and brands.
This Policy applies to personal data collected both online and offline, including through our websites (“sites”), mobile or social media applications (“apps”), consumer engagement centres, promotions, events, correspondence and any other services that refer to this Policy. Our sites, apps and other digital services are together referred to in this Policy as the “Services”.
This Policy is divided into the following sections:
Tropicana Products UK Ltd, company number 13650169, whose registered office is at 10 Fetter Lane, London EC4A 1BR, is the controller responsible for the personal data covered by this Policy. References to “Tropicana”, “we”, “us” or “our” mean Tropicana Products UK Ltd.
Tropicana is part of the Tropicana Brands Group. Other Tropicana Brands Group companies may process personal data on our behalf, provide services supporting our UK activities or, in some circumstances, act as separate controllers.
Where another group company or third party is separately responsible for deciding how and why personal data is used, that organisation will be responsible for its own processing and privacy information. This may occur, for example, where we conduct a joint promotion with a retailer or another commercial partner. We will provide or direct you to any additional privacy information required in those circumstances.
Data protection compliance is managed by Legal / Privacy Europe. You can contact us using the details in the “Contact us” section below.
This Policy applies where you interact with us as:
Where we collect personal data in a specific context, we may provide additional or more specific privacy information. Job applicants should read our Recruitment Privacy Notice [insert link] for job applicants).
This Policy should also be read together with our Cookie Policy and our Data Protection Complaint Handling Policy.
Personal data means any information that relates to an identified or identifiable individual.
We may also collect, use and share aggregated or statistical information. Aggregated information may be derived from personal data but is not personal data where it does not directly or indirectly identify an individual. If we combine aggregated information with personal data so that an individual can be identified, we treat the combined information as personal data in accordance with this Policy.
We may collect personal data through our consumer engagement centres, marketing activities, promotions, competitions, sites, apps, branded pages on third-party platforms, surveys, events and business relationships. Recruitment-related personal data is covered by our separate Recruitment Privacy Notice.
We may collect personal data from a variety of sources. This includes:
Identity and contact data
We may collect your name, title, postal address, email address and telephone number. We may also collect online identifiers such as an account name, username or social media identifier.
Depending on the activity, we may also collect your age, date of birth or other information required to verify your identity, eligibility or authority to act for another person.
Financial and Transaction Data
If you purchase a product or service directly from us, receive a refund or otherwise enter into a financial transaction with us, we, or our payment-service providers may process payment, bank-account, transaction, delivery and refund information.
Where a payment provider collects payment-card information directly, Tropicana may receive only limited transaction information rather than your complete payment-card details.
Content and Consumer Interaction Data
We collect information you submit or otherwise provide or authorise us to collect. This may include information you post in a public area of one of our sites or Services such as comments, videos or photos. We may also collect information you provide when you sign up for a marketing newsletter, complete a survey, enter a competition or communicate with us through our online or offline channels.
This may include:
Profile and Demographic Data
We may collect information such as your gender and age, household or lifestyle information, postcode, interests, product preferences and purchasing or interaction history.
We will explain where providing particular demographic or preference information is voluntary.
Marketing and Communications Data
We may collect information about your preferences for receiving marketing from us or third parties, your preferred methods of communication, your marketing consents and objections, and your interactions with our marketing communications.
Technical and usage data
We may collect information about:
Some of this information may be collected through cookies and similar technologies. For information about the technologies we use, their purposes and duration, and how you can manage your choices, please see our Cookie Policy and use the “Cookie Preferences” link available on the site.
Business data
Where you act for or work with a customer, retailer, distributor, supplier, service provider, professional adviser or another business, we may collect:
Data rights and complaints data
Where you exercise a data protection right or make a data protection complaint, we may collect:
Information about other people
You may provide personal data relating to another person as part of an enquiry, complaint, promotion, rights request or other interaction with us. Please provide another person’s personal data only where you are entitled to do so and only to the extent necessary for the relevant purpose.
We will not use contact details supplied through a “refer a friend” or similar feature to send direct marketing to that person unless the requirements of applicable direct-marketing law have been met.
Special categories of personal data
Certain personal data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data, biometric data used to identify a person, health, sex life or sexual orientation is classified as “special category data” personal data and is subject to additional protection under UK data protection law.
We limit the circumstances where we collect and process these special categories of data.
You may choose to provide health information when contacting us about an experience with a product, including information about allergies, dietary requirements or a possible adverse reaction. Information about dietary preferences will constitute health data where it reveals information about your physical or mental health.
We process special category personal data only where we have both a lawful basis for the processing and an additional condition permitted by UK data protection law. Depending on the circumstances, the additional condition may be:
Where we rely on explicit consent, you may withdraw it at any time. Withdrawal will not affect the lawfulness of processing carried out before consent was withdrawn.
Criminal-offence data
We do not routinely collect information about criminal allegations, proceedings, convictions or offences. We may process such information where it is relevant to fraud prevention, security, an investigation, due diligence or legal proceedings and where the processing is permitted by the Data Protection Act 2018.
If you do not provide personal data
Where we need personal data to enter into or perform a contract with you, administer a promotion or comply with a legal obligation, failure to provide the required information may mean that we cannot provide the relevant product, service, prize, payment, response or other benefit. We will tell you where particular information is required and, where appropriate, explain the consequences of not providing it.
We collect information from you when you:
We collect information automatically
We collect certain technical and usage information automatically when you use our sites, apps and other digital Services. Some of this information is collected through cookies and similar technologies. Further information is provided in our Cookie Policy.
Third parties may also provide information about you
For example, our business partners may give us information about you. We may receive information from companies who compile information about shoppers and their preferences. Social media platforms may also give us information about you, and we may get information about your interactions with our ads on third-party sites.
Other sources may include:
Where required by law, we will provide any additional privacy information relating to personal data obtained from another source.
We combine information from different sources
We may combine personal data collected through different Services, devices, group companies or third parties. We do so only for the purposes described in this Policy and where we have an appropriate lawful basis.
For example, we may combine customer-service records with product or promotion information to respond to an enquiry or combine information about your marketing preferences with information about your interactions with our communications.
We will normally use personal data only for the purposes for which it was collected. We may use it for another purpose where that purpose is compatible with the original purpose. If we need to use personal data for an unrelated purpose, we will inform you and explain the lawful basis that permits the new use, unless the law allows or requires us to process the information without doing so.
We use personal data to provide products, services and support
We use your information to respond to your questions or enable you to participate in our programmes. This may include promotions, prize draws or competitions.
We may also your personal data to:
We use personal data to improve our products and services
We may use your personal data to improve your experience with our sites, apps, and products, and, where permitted, personalise your experience and provide product recommendations.
We may also use personal data to:
We use anonymised or aggregated information where reasonably possible.
We use personal data for security and fraud prevention purposes
We may use your personal data to protect you, our company, our customers, our consumers, business partners, our systems and our Services.
This includes:
We use personal data for marketing purposes
We may send you information about our products, brands, offers, features, or updates. We may also use your personal data to select or display advertisements about Tropicana Brands Group products and offers on our Services or on third- party platforms including social media.
We may analyse Identity and Contact Data, Profile and Demographic Data, Technical and Usage Data and Marketing and Communications Data to understand which products, communications or offers may be relevant to you.
You may object to direct marketing at any time. Please see “Your legal rights” below.
We send marketing emails, text messages and similar electronic communications to individual subscribers only where you have consented or where the communication is otherwise permitted by law. For example, we may rely on the “soft opt-in” where we obtained your contact details directly in connection with a sale or negotiations for a sale, the marketing concerns our own similar products or services, and we offered a clear opportunity to opt out when the details were collected and in each subsequent communication.
We may send relevant business-to-business marketing to contacts at companies and other corporate organisations where permitted by law. You may object to direct marketing or use the unsubscribe mechanism provided.
We will obtain your express consent before disclosing your personal data to an independent third party for that third party’s own direct-marketing purposes.
Where personal data is used for marketing or profiling is collected through cookies or similar technologies, please see our Cookie Policy for further information and to manage your choices.
We use personal data for feedback and administrative communications purposes
We may contact you about:
We use personal data to manage business relationships
Where you act for or work with a customer, retailer, distributor, supplier, service provider, professional adviser or other organisation, we may use your personal data to:
We use personal data to deal with data protection rights requests and complaints
We use personal data to:
We use personal data for legal and corporate purposes
This includes:
We will use personal data only where we have a lawful basis under UK data protection law. Depending on the activity, we may rely on one or more of the following bases:
Where we rely on legitimate interests, we consider the nature and purpose of the processing, whether it is necessary and the potential effect on you. We do not rely on legitimate interests where your interests, rights or freedoms override those interests.
Using your personal data for a new purpose. Before we use your personal data for a new purpose, we will check that the new purpose is compatible with the original purpose, or that we have another lawful basis (or your consent) for it, in line with the purpose-limitation rules in the UK GDPR as amended by the Data (Use and Access) Act 2025. Certain further uses, such as scientific or historical research, archiving in the public interest, and statistical purposes, may be treated as compatible where appropriate safeguards are in place.
| Purpose / Use | Type of data | Legal basis |
|---|---|---|
| To register you on our sites or apps and administer loyalty programmes | Identity; Contact; Profile and Demographic Data | Performance of a contract with you; legitimate interests in administering accounts and programmes |
| To provide products and services, process and deliver orders, samples, refunds, prizes or other requested items | Identity; Contact; Financial; Transaction Data; Consumer Interaction Data | Performance of a contract; legitimate interests in administering transactions and recovering sums due |
| To run competitions, prize draws, and promotions, | Identity and Contact Data; Profile and Demographic Data; Consumer Interaction Data; Marketing and Communications Data | Performance of a contract; legitimate interests in administering and evaluating the activity, and protecting it against fraud or misuse; consent where separately required |
| To conduct surveys, consumer panels, market research and events | Identity and Contact Data; Profile and Demographic Data; Content and Consumer Interaction Data; Marketing and Communications Data | Legitimate interests in conducting research, understanding consumer preferences and improving our products and brands; performance of a contract where applicable; consent where separately required |
| To respond to consumer enquiries, product complaints, safety concerns and possible adverse reactions | Identity and Contact Data; Consumer Interaction Data; Transaction Data; Special Category Data where relevan | Performance of a contract where relevant; legitimate interests in responding to consumers, resolving concerns, maintaining product quality and improving our products; legal obligation where applicable. An additional special category condition will also be required where health data is processed |
| To manage our relationship with you and notify you about changes to this Policy, our Services or applicable terms | Identity and Contact Data; Profile and Demographic Data; Marketing and Communications Data; Consumer Interaction Data | Performance of a contract; legal obligation; legitimate interests in managing the relationship and keeping appropriate records |
| To receive and respond to data protection rights requests and complaints | Identity and Contact Data; Rights and Complaints Data; any other data relevant to the request or complaint | Legal obligation; legitimate interests in preventing unauthorised disclosure, investigating and resolving concerns, protecting legal rights and demonstrating compliance |
| To manage business, customer and supplier relationships | Identity and Contact Data; Business Data; Financial and Transaction Data | Performance of a contract where you are personally a party to it; legal obligation; legitimate interests in managing commercial relationships, procurement, supply chains, accounts, performance and business operations |
| To administer and protect our business and Services, including troubleshooting, testing, maintenance, security and fraud prevention | Identity and Contact Data; Technical and Usage Data; Business Data; Consumer Interaction Data | Legal obligation where applicable; legitimate interests in operating our business, providing IT and administrative services, protecting systems, preventing fraud and misuse and maintaining business continuity |
| To deliver relevant content and advertising and measure its effectiveness | Identity and Contact Data; Profile and Demographic Data; Technical and Usage Data; Marketing and Communications Data | Legitimate interests in understanding consumer interests, personalising content, developing our products and measuring our communications; consent where we rely on consent for the processing |
| To use analytics to improve our sites, apps, products, services and communications | Technical and Usage Data; Profile and Demographic Data; Consumer Interaction Data | Legitimate interests in analysing use of our Services, keeping them relevant, improving products and services and developing our business |
| To send direct marketing and make personalised recommendations | Identity and Contact Data; Profile and Demographic Data; Technical and Usage Data; Marketing and Communications Data | Consent where required or where we choose to rely on consent; otherwise legitimate interests in promoting our products and brands, including where the products and services soft opt-in or the corporate-subscriber rules apply |
| To comply with law, respond to legal process, prevent or investigate wrongdoing and establish, exercise or defend legal claims | Any personal data relevant to the matter | Legal obligation; legitimate interests in protecting our business and legal rights, obtaining advice, managing risk and preventing or investigating fraud or unlawful conduct; vital interests in an emergency |
| To process and manage job applications | Job Application Data; Identity; Contact | Steps at your request prior to a contract; legal obligation; legitimate interests — see our Recruitment Privacy Notice [insert link] |
| To support corporate transactions and reorganisations | Identity and Contact Data; Business Data; Financial and Transaction Data; other data relevant to the transaction | Legitimate interests in evaluating and implementing corporate transactions, restructuring and business continuity; legal obligation where applicable |
Third-party marketing
We will obtain your express consent before sharing your personal data with any company outside the Tropicana Brands Group for that company's own direct marketing purposes.
Opting out of marketing
You can ask us to stop sending you marketing communications at any time by:
If you opt out of marketing, you may continue to receive non-marketing communications where necessary, such as responses to enquiries, information about a promotion you have entered or notices relating to our terms.
We may retain limited information on a suppression list so that we can continue to respect your marketing objection or opt-out.
We share information within the Tropicana Brands Group
We may share personal data with other Tropicana Brands Group companies for:
Where a group company processes personal data on our behalf, it must process the data in accordance with our instructions and applicable confidentiality and security requirements.
This includes current and future Tropicana Brands Group subsidiaries, affiliates, and joint venture partners. This also includes current brands such as Tropicana, Naked, Copella, and other Tropicana Brands Group brands.
Where another group company acts as a separate controller, it is responsible for its own processing and privacy information.
We may also share information with third parties with which we have an ownership interest or commercial relationship, such as companies whose products we distribute.
We share information with our business partners and third-party providers
We may share personal data with:
Where we run a joint promotion or activity with a retailer or another partner, your personal data may be collected by both Tropicana and that partner. The partner’s use of your personal data will be governed by its own privacy information.
Where a service provider processes personal data on our behalf, we require it to:
Some recipients, including regulators, public authorities, payment providers and professional advisers, may act as independent controllers and will be responsible for their own compliance with data protection law.
We will disclose your personal data where required or permitted by law
We may share personal data:
We may share personal data for corporate transactions
We may disclose personal data in connection with a proposed or completed merger, acquisition, financing, reorganisation, insolvency, sale of assets or transfer of all or part of our business.
If a change of ownership occurs, the new owner may use your personal data in the manner described in this Policy, unless it provides you with different privacy information..
If there are additional reasons we may share information, we will describe those to you where required by law.
Your personal data may be transferred to, and processed in, countries other than the United Kingdom, including countries in which Tropicana Brands Group companies and our service providers operate such as Belgium, Canada, France, German, India, Ireland, Netherlands, Nicaragua Switzerland and the United States of America. These countries may have data protection laws that are different from UK data protection law.
Whenever we make a restricted transfer of personal data outside the UK, we ensure that the transfer is made in accordance with UK data protection law. Depending on the recipient and destination, we may rely on:
Where we rely on contractual or other appropriate safeguards, we carry out the required transfer risk assessment or “data protection test”, as required by law to assess whether the transferred personal data will receive a standard of protection that is not materially lower than the protection provided in the UK. We put additional contractual, organisational or technical measures in place where necessary.
We may analyse profile and demographic data, technical and usage data, information about your purchases or interactions, and marketing and communications data to create audience segments or infer matters such as your likely interests and preferences.
We may use those segments to personalise content or communications, make product recommendations, select advertisements or measure the effectiveness of our marketing.
Where profiling relies on information collected through cookies or similar technologies, it is subject to the choices described in our Cookie Policy. We may also use information about whether you open or interact with our marketing communications to measure their effectiveness and tailor future communications, where permitted by law.
This profiling does not currently result in decisions that produce legal or similarly significant effects on you. You may object at any time to profiling carried out for direct-marketing purposes and may object, on grounds relating to your particular situation, to other profiling based on legitimate interests.
We do not currently make decisions about you based solely on automated processing that produce legal effects or similarly significant effects.
If this changes, we will update this Policy or provide additional privacy information before carrying out that processing and will put in place the safeguards required by law, including measures enabling you to make representations, obtain human intervention and contest the decision.
You have a number of rights under UK data protection law. These rights are subject to statutory conditions and exemptions and may not apply in every case.
You may have the right to:
No fee usually required
You will not normally have to pay a fee to exercise your rights.
We may charge a reasonable fee for the administrative costs of complying with a request where it is manifestly unfounded or excessive or where you request further copies of personal data following an earlier request. Alternatively, we may refuse to comply with a manifestly unfounded or excessive request.
What we may need from you
We may ask for information reasonably necessary to confirm your identity and ensure that personal data is not disclosed to a person who is not entitled to receive it.
Where someone makes a request on your behalf, we may ask for evidence that the person is authorised to act for you.
We will not request more information than is reasonably necessary for these purposes.
Time limit for responding
We will respond to a rights request without undue delay and normally within one month.
We may extend the response period by up to two further months where the request is complex or you have made a number of requests. We will tell you within the initial one-month period if an extension is required and explain why.
The following rules apply specifically to a request for access to personal data:
To stop receiving promotional emails, or other electronic marketing, follow the unsubscribe or opt-out instructions in the communication or contact us. For information about managing cookies and similar technologies, please see our Cookie Policy and use the “Cookie Preferences” link available on the relevant site.
Our sites and apps are not generally intended for children under 13, and we do not knowingly collect personal data directly from children under 13 through those Services without appropriate parental or guardian consent where such consent is required.
Some of our products or content may appeal to children. Where a Service is likely to be accessed by children, we take children’s needs into account when deciding how their personal data will be used and apply appropriate age-related transparency, minimisation and other safeguards.
Where a particular promotion, activity or Service is intended for children or young people, we may provide additional age-appropriate privacy information and apply specific eligibility or consent requirements.
If you are a parent or legal guardian and think that your child has given us information, you can contact us at privacyeurope@tropicana.com and we will take appropriate steps. You can also write to us at the address listed below.
Please mark your inquiries “GDPR Article 8 - Children's Privacy.”
We have put in place appropriate technical and organisational measures designed to protect personal data against accidental or unlawful loss, destruction, alteration, unauthorised disclosure or access.
We limit access to personal data to employees, agents, contractors, group companies and other third parties that have a business need to know it. Those processing personal data on our behalf are required to follow our instructions and are subject to appropriate confidentiality obligations.
We have procedures for responding to suspected personal data breaches and will notify affected individuals and the Information Commissioner’s Office where we are legally required to do so.
We retain your personal data we collect from you only for as long as reasonably necessary for the purpose for which it was originally collected, including to meet applicable legal, regulatory, tax, accounting, audit, insurance, reporting, complaint-handling and legal-claims requirements.
To determine the appropriate retention period, we consider:
By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data). Certain contractual, transaction, accounting or tax records may be retained for six years or another applicable statutory period.
We may retain personal data for a longer where:
Where you object to or opt out of direct marketing, we may retain limited suppression information for as long as necessary to ensure that we continue to respect your choice.
Retention periods for cookies and similar technologies are set out in our Cookie Policy.
We retain the personal data we collect directly for targeting purposes for as little time as possible, after which we employ measures to permanently delete it.
We regularly review the personal data we hold and delete it securely, or in some cases anonymise it, when there is no longer required. Where we irreversibly anonymise personal data so that it can no longer be associated with you, we may retain and use the anonymised information without further notice. Where immediate deletion from backup systems is not reasonably possible, the information will remain protected and will not be used for ordinary business purposes while awaiting deletion in accordance with our backup cycle.,
Our Services may contain links to third-party websites, platforms, applications, plug-ins, content or services.
Our sites and apps may also include third-party content that collects information. Third party content may include tools like cookies and tracking technologies. These third parties may use your information for their own purposes. This may include behavioural advertising and analytic purposes. We do not control these third parties or their use of these technologies, so please read their privacy policies carefully. Clicking on third-party links or enabling third-party connections may allow those parties to collect or share data about you.
We do not control third-party services and are not responsible for their privacy practices. When you leave our Services or interact with third-party content, we encourage you to read the relevant third party’s privacy information.
Further information about third-party cookies and similar technologies used through our sites is provided in our Cookie Policy.
If you have questions about this Policy or our processing of personal data or your legal rights, please contact:
Email: privacyeurope@tropicana.com.
Post:
Tropicana Products UK Ltd. Attn: Consumer Relations 10 Fetter Lane,
London EC4A 1BR.
If you are concerned about how we handle your personal data, you may make a data protection complaint to us.
You may submit a complaint through:
Full details of the process are set out in our Data Protection Complaint Handling Policy.
We will:
Where your communication includes both a complaint and a request to exercise a data protection right, we will handle each element under the applicable process.
You also have the right to complain to the Information Commissioner’s Office, the UK data protection regulator.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Telephone: 0303 123 1113
Website: www.ico.org.uk
You may complain to the Information Commissioner’s Office at any time. You do not have to complain to Tropicana first, although we would welcome the opportunity to consider and respond to your concerns.
From time to time, we may change this Policy. When we do, we will post an updated copy and revise the “Last Updated” date.
Where required by law, we will also take appropriate steps to bring material changes to your attention.
We keep this Policy under regular review. Historic versions may be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please tell us if relevant personal data changes during your relationship with us.
Where To Find Us
Get In Touch
Tropicana Brands Group PO Box 3270, READING, RG1 9PE UK: 08001114555
ROI: 1800851685
tbgcares@tropicana.com
© 2025 Tropicana Products, Inc. All Rights Reserved.