PRIVACY POLICY

General
Concentrate Manufacturing (Singapore) Pte. Ltd. (“PepsiCo”), values the privacy of all our
customers. We take very seriously the need to respect and protect your privacy and the security of
any information you may share with us. This Privacy Policy (“Policy”) describes the data collection,
use, disclosure and processing practices of PepsiCo, in connection with the Website
www.dewpowerup.com [hereinafter, “Website”]
Please carefully read and understand this Policy.
Scope and Acceptance of this Privacy Policy
By joining the promo, you expressly consent to the collection, use, disclosure and processing of your
Personal Data in accordance with this Policy.
Moreover, by opting in to receive promotional and marketing materials, you give permission to
PepsiCo to send you, from time to time, direct and indirect marketing materials and advertising
information on products and services available from PepsiCo, its affiliates, and business partners,
based on your customer profile and behavior and to contact you via surveys to conduct research
about your opinion of current services or of potential new services that may be offered. When
PepsiCo contacts you on behalf of its subsidiaries, affiliates and business partners, your unique
personally identifiable information (e-mail, name, address, telephone number) is not transferred to
such third party.
This Policy applies to Personal Data collected only directly through or from the Website. It does not
apply to Personal Data collected from offline resources and communications, such as information
you may send to us in a postal letter or give to us in a phone call. This Policy also does not apply to
third-party online resources to which PepsiCo Websites may link, because PepsiCo does not control
their content or their privacy practices.
Collection of your Personal Data
PepsiCo collects the following Personal Data through this Website:
● personally identifiable information, your e-mail address, name, social media account details,
home or work address and telephone/cellphone number;
● anonymous demographic information, which is not unique to you, such as your ZIP code, age,
gender, preferences, interests and favorites; information about your computer hardware and
software that are automatically collected by PepsiCo namely: your IP address, browser type,
domain names, access times and referring Website addresses used by PepsiCo for the
operation of the service, to maintain quality of the service, and to provide general statistics
regarding use of the Website.
When you register with PepsiCo’s Website by joining the Promo, we use your Personal Data to
create a customized Web experience for you and to improve our services and (i) improve the content
and layout of the Website, or (ii) develop products, marketing, and promotions internally at PepsiCo.
PepsiCo keeps track of the Websites and pages our customers visit within PepsiCo, in order to
determine what PepsiCo services are the most popular. This data is used to deliver customized
content and advertising within PepsiCo to customers whose behavior indicates that they are
interested in a particular subject area.
In relation to the Personal Data, PepsiCo is the personal information controller (“PIC”) which
means that it determines what information is collected, or the purpose or extent of the processing of
the Personal Data.
Please keep in mind that if you directly disclose Personal Data through PepsiCo public message
boards, this information may be collected and used by others. PepsiCo does not read any of your
private online communications.
All voluntarily declared Personal Data posted by an individual in public areas on the Website, such as
chat rooms or bulletin boards is disclosed at the risk of the user and PepsiCo shall not be
responsible or liable for any misuse of such voluntarily disclosed Personal Data. PepsiCo will,
however, use, disclose or process such Personal Data only as provided herein.
While PepsiCo may monitor or review the information posted to the public areas of the Website, it
is under no obligation to do so and assumes no responsibility or liability arising from the content of
such public areas of the Website in general or for any error, defamation, libel, slander, omission,
falsehood, obscenity, pornography, profanity, danger, or inaccuracy contained in the Website.
PepsiCo encourages you to review the privacy statements of Websites you choose to link to from
PepsiCo so that you can understand how those Websites collect, use and share your information.
PepsiCo is not responsible for the privacy statements or other content on Websites outside of the
Website. We do not collect financial or other sensitive data/information from our users. PepsiCo will
not collect any Personal Data about you through this Website unless you have provided it to us
voluntarily.
Purposes of Data Processing
PepsiCo collects, uses and otherwise processes your Personal Data:
● to operate the Website and otherwise execute efforts to improve Website user satisfaction;
● to host our services and maintain our data storage facilities;
● to deliver the services you have requested;
● to conduct research and analytics;
● to provide you with information you have requested or agreed to receive, including
promotional and marketing materials to inform you of other products or services available
from PepsiCo, its affiliates and business partners;
● to contact you via surveys to conduct research about your opinion of current services or of
potential new services that may be offered by PepsiCo, its affiliates and business partners;
● to investigate complaints, reply to inquiries or resolve issues;
● to collect data for the raffle component of the said promo;
● to comply with legal requirements or processes or governmental requests such as in response
to a court order or a subpoena; and
● in case of merger, acquisition or other public offering of all or part of the business or assets of
PepsiCo.
Scope and Method of Collection and Processing
We use standard manual and computerized methods and systems to file, store and process Personal
Data. Collection and processing of Personal Data shall be in accordance with the principles of this
Policy and as required by law.
Transfers or Disclosure of Personal Data to Third Parties

Third-Party Service Providers

Your Personal Data may be transferred or disclosed to third parties that PepsiCo has engaged to
enable it to achieve the purposes set out above, including but not limited to Trusted Partners who
provide us services and assist us to:
● perform statistical analysis
● send you email or postal mail
● provide customer support, or
● arrange for deliveries.
All such Trusted Partners are third-party service providers which are prohibited from using your
Personal Data except to provide these services to PepsiCo and are required to maintain the
confidentiality of your information. Any Personal Data outsourced to such third-party service
providers are subject to appropriate written agreements specifying that Personal Data shall only be
processed upon the documented instructions of PepsiCo, imposing an obligation of confidentiality
on persons authorized to process the Personal Data, and implementing appropriate security
requirements for compliance with the DPA including the conduct of annual audits of such service
providers to ensure adequate safeguards are implemented by such service providers.
Some of these entities may be outside the Philippines and the transfer of Personal Data to them shall
be cross-border.
Disclosure of Aggregate Information
On occasion, aggregate information, that does not identify any particular user may be complied and
shared with subsidiaries and affiliates of the Company, strategic partners, merchants and advertisers.
PepsiCo does not sell, rent or lease its customer lists to third parties.
Aside from age and gender which are collected, used and processed as provided in this Policy,
PepsiCo will not use or disclose other Sensitive Personal Information, such as race, religion, or
political affiliations, without your explicit consent.
Please note that PepsiCo does not request Personal Data by sending e-mails. We only collect such
information on our Website. If you receive an e-mail purporting to be from us that solicits Personal
Data, do not respond to it.
PepsiCo will disclose your Personal Data, without notice, only if required to do so by law or in the
good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with
legal process served on PepsiCo or the site; (b) protect and defend the rights or property of
PepsiCo; and, (c) act under exigent circumstances to protect the personal safety of users of PepsiCo,
or the public.

Retention of Personal Data

We shall retain and use your Personal Data as long as necessary for the fulfillment of the purposes
for which the information was obtained, or for the establishment, exercise or defense or legal claims,
or for legitimate business purposes, or as provided by law.
Security of Personal Data
The security, confidentiality, integrity and availability of your Personal Data are important to
PepsiCo. We strictly enforce and implement administrative, technical, organizational and physical
security measures for the protection of Personal Data against accidental loss or destruction, unlawful
or unauthorized access and disclosure, fraudulent misuse, alteration and contamination of the
Personal Data you provide on this Website. We use secure socket layer (SSL) technology to help
keep the Personal Data you provide on this site secure.
Rights of Data Subjects
As a data subject, you have the following rights under the Data Privacy Act (“DPA”):
● The right to access. Upon your request, you may be provided access to your Personal Data
that we collect and process. You also have the right, insofar as allowed by law, to request
access to the circumstances relating to the collection and processing of your Personal Data.
● The right to make corrections. You have the right to dispute the inaccuracy or error in the
Personal Data and have us correct it immediately and accordingly, unless the request is
vexatious or otherwise unreasonable.
● The right to object. You have the right to object to the processing of your Personal Data,
including processing for direct marketing, automated processing or profiling. You also have
the right to be notified and given an opportunity to withhold consent to further processing in
case of amendment to the information supplied to you. Once you object or withhold consent,
we will no longer process the Personal Data unless:
o The Personal Data is needed pursuant to a subpoena;
o The collection and processing are undertaken pursuant to any lawful basis or as a result
of, or when necessary in relation to, a legal obligation or other criteria where the data is
not covered by the DPA.
You may at any time opt-out of receiving direct and indirect marketing materials and
advertising information on products and services available from PepsiCo, its affiliates, and
business partners, by clicking on icons on the account profile page, or clicking on the
unsubscribe button in the e-mail or by otherwise sending your request to the Data Protection
Officer’s contact email as provided below. However, if you ask us to stop collecting, using,
disclosing or processing your Personal Data, we may not be able to offer you certain services
available only to those who do register certain Personal Data on the Website.
● The right to erasure or blocking. You have the right to suspend, withdraw or order the
blocking, removal or destruction of your Personal Data from our filing system (i) if there is no
other legal ground or overriding legitimate interest for the processing, or (ii) when there is
substantial proof that your Personal Data is incomplete, outdated, false, unlawfully obtained,
used for a purpose not authorized, or no longer necessary for the purposes for which they
were collected. We may notify third parties who have previously received such processed
Personal Data.
● The right to damages. You have the right to be indemnified for any damages sustained due to
inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of Personal
 Data, taking into account any violation of your rights as a data subject as provided by the
DPA.
● The right to lodge a complaint. You have the right to lodge a complaint with the National
Privacy Commission (“NPC”) subject to its guidelines for the exercise of such right.
● The right to data portability. Where your Personal Data is processed by electronic means and
in a structured and commonly used format, you have a right to obtain a copy of such data in
an electronic or structured format that is commonly used and allows for your further use,
subject to the NPC’s standards, procedures and other rules for the exercise of such right.
● Transmissibility of rights of the data subject. Should you pass away or be incapacitated or
incapable of exercising your rights above, your lawful heirs and assigns may invoke your rights
in your stead.
● Limitation on rights. The immediately preceding rights are not applicable if your processed
Personal Data are used only for the needs of scientific and statistical research and no activities
are carried out or no decisions are taken in relation to you, on the basis of such data. Your
rights as a data subject remain shall be subject to all other limitations provided by law.

Minors or Persons under the Age of Eighteen (18)

PepsiCo does not knowingly solicit, collect, use, disclose or process Personal Data of minors below
eighteen (18) years of age without obtaining prior consent from a person with parental responsibility.
Minors must review the Policy with their parents or guardians who shall agree to the Policy in order
for such minors to use this Website. Consent provided to this Policy is assumed to have been given
by persons aged eighteen (18) and above. PepsiCo shall not, under any circumstances, be liable for
any consequences, legal or otherwise, arising from any misrepresentation and/or false information
provided to it regarding the age of the data subject.

User-Generated Content Functions

This Website enables users to submit their own content. Please remember that any information you
disclose in connection with a submission becomes public information and you should exercise
caution when deciding to disclose your Personal Data including financial or other information in a
submission. PepsiCo cannot prevent such information being used in a manner that may violate this
Privacy Policy, the law, or your personal privacy and safety and is not responsible for the results of
such posting.
"Cookies" - What Information Is Being Stored?
The Website uses "cookies" to help you personalize your online experience. A cookie is a text file
that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or
deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a
web server in the domain that issued the cookie to you.
You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies,
but you can usually modify your browser setting to decline cookies if you prefer. If you choose to
decline cookies, you may not be able to fully experience the interactive features of Websites you visit.
As most Websites do, we do track usage patterns on our Website on an anonymous basis. Your
identity cannot reasonably be ascertained from this information. Each time you visit our Website,
our server records your Internet Service Provider, the date and time of your visit, the pages you visit
and the documents downloaded, the searches you performed, and the referring URL's you came
from. We use this non-Personal Data to optimize our Website service.
Changes To This Statement
PepsiCo reserves the right to change this Privacy Statement at any time and we will take reasonable
steps to advise you of any material changes. PepsiCo will occasionally update this Statement of
Privacy to reflect company and customer feedback. PepsiCo encourages you to periodically review
this Statement to be informed of how PepsiCo is protecting your information.
Contacting Us
If you have any queries about this Policy and our use of Personal Data, have suggestions on how we
may improve the Policy, or wish to have access to your Personal Data in our records, please contact
PepsiCo’s Data Protection Officer (“DPO”) through the contact details provided below:
PepsiCo
Attention: Data Protection Officer
Email: www.dewpowerup.com - support@dewpowerup.com

Updates to Policy
PepsiCo reserves the right to change this Privacy Policy at any time and we will take reasonable steps
to advise you of any material changes. PepsiCo will occasionally update this Policy to reflect
company and customer feedback. PepsiCo encourages you to periodically review this Policy to be
informed of latest updates. This Policy was last updated on 6 August 2018.
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