Privacy Notice

Starbucks · Official agreement

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15 of 100 cards in Sharing & Disclosure

Sharing & Disclosure · Company practice

Uses to send personalized promotions and marketing, including sharing with business partners so they can email you

Starbucks may use information to send you personalized promotions, content and special offers, and to communicate about its brands, products, events or other promotional purposes. It also lists, as a way of implementing your communications preferences, "sharing information with Starbucks business partners so that they may email you about their promotions, products and initiatives". So marketing use includes sharing information with business partners for their own emails, not only Starbucks' own messages.

Supporting quotations

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

Qualifications & exceptions

  • Worded "may"
  • The sharing with business partners is described as implementing your communications preferences, "such as" an example

Not stated here

  • The Notice does not say which of your preferences lead to sharing with business partners, or which partners

Sharing & Disclosure · Company practice

Starbucks may disclose information to the third parties described, for the Notice's purposes and as the law permits

Starbucks says it may disclose information about you to the third parties described in this section, for the purposes outlined in the Notice and as permitted by applicable law. The recipients are affiliates and subsidiaries, service providers, business partners, advertising and analytics providers, parties to corporate transactions, authorities and others as legally required or permitted, people you direct it to share with, and the public where you post.

Supporting quotations

We may disclose information about you to the third parties described below for the purposes outlined in this Notice and as permitted by applicable law.

Qualifications & exceptions

  • Worded "may disclose"
  • Limited to "the purposes outlined in this Notice and as permitted by applicable law"

Sharing & Disclosure · Company practice

Sharing within Starbucks Corporation, its subsidiaries and affiliates

Starbucks may share information between and among Starbucks Corporation, its subsidiaries and its affiliates for management and analysis, decision making and other business purposes. Examples given are administering loyalty programs, processing orders and requests, and expanding and promoting its product and service offerings.

Supporting quotations

We may share information between and among Starbucks Corporation, its subsidiaries, and affiliates for purposes of management and analysis, decision making, and other business purposes.
we may share your information with our subsidiaries and affiliates to administer our loyalty programs, process orders and requests, and expand and promote our product and service offerings

Qualifications & exceptions

  • Worded "may share"
  • The purposes are open-ended ("other business purposes"); the examples are introduced by "for example"

Sharing & Disclosure · Company practice

Sharing every collected category with service providers for a wide range of business purposes

Starbucks may share each of the categories of information described in the "Information We Collect" section with service providers that perform services for it or on its behalf. The services listed include payment processing, website and data hosting, location mapping, product and service delivery, customer service, advertising and marketing services, running sweepstakes and Starbucks Rewards benefits and communications, compliance with industry standards, analytics, security and performance monitoring, maintaining accounts, professional advisors such as auditors and lawyers, fulfilling orders, verifying customer information, research, auditing and data processing. The list is long and broad, and the sentence says "each of the categories", so no collected category is carved out in this section.

Supporting quotations

We may share each of the categories of information described, in the “Information We Collect” section, for a variety of business purposes with our service providers who provide an array of services for us or on our behalf, such as payment processing, website and data hosting, location mapping, product and service delivery, customer service, advertising and marketing services, facilitating sweepstakes and Starbucks® Rewards loyalty program benefits and communication, ensuring compliance with industry standards, analytics services, security and performance monitoring, maintaining and servicing accounts, professional advisors (such as auditors and lawyers), processing or fulfilling orders and transactions, verifying customer information, research, auditing, and data processing.

Qualifications & exceptions

  • Worded "may share"
  • Applies to "each of the categories of information" in section 2, which includes the categories the Notice marks as potentially sensitive
  • Recipients are providers who serve Starbucks "or on our behalf"

Not stated here

  • This section does not say which providers receive which categories

Sharing & Disclosure · Company practice

Fraud protection suppliers, including Ekata, which acts as a controller under its own privacy notice

Starbucks may share your personal information with service providers that help protect you and Starbucks from fraud. It names Ekata, Inc. as one such supplier, and says Ekata uses the information as a controller for the benefit of Starbucks and others in accordance with its own privacy notice. The Notice therefore points to Ekata's own notice, not this one, as the stated basis for Ekata's use of the information.

Supporting quotations

We may share your personal information with service providers who help to protect you and Starbucks from fraud.
One such supplier is Ekata, Inc., which uses the information as a controller for the benefit of Starbucks and others in accordance with its privacy notice located at

Qualifications & exceptions

  • Worded "may share"
  • Ekata is described as using the information as a controller, for the benefit of Starbucks and others

Not stated here

  • Ekata's privacy notice is not supplied here, so this card cannot say what Ekata does with the information

Sharing & Disclosure · Company practice

Sharing with independent business partners, whose practices the Notice does not cover

To make certain products, services and experiences available, Starbucks works with independent business partners such as co-branded loyalty and rewards partners, delivery partners, and authorized distributors or licensees. When you obtain products or services from these partners, Starbucks may share your information with them, or you may give it to them directly. It may also share information with independent partners when they sponsor sweepstakes, contests, events and other promotions together. The Notice says it does not address, and is not responsible for, the privacy or other practices of these partners, and encourages you to read their privacy notices.

Supporting quotations

we work closely with independent business partners, including, for example, co-branded loyalty and rewards partners, delivery partners, and partners who are authorized distributors of our products or licensees
we may share your information with them, or you may provide it to them directly
We may also share your information with independent business partners when we work with them to sponsor sweepstakes, contests, events, and other promotions.
This Notice does not address, and we are not responsible for, the privacy, information, or other practices of these business partners.

Qualifications & exceptions

  • Worded "may share"
  • Sharing is described for partners whose products or services you obtain, and for jointly sponsored promotions
  • The Notice disclaims responsibility for the partners' own practices

Not stated here

  • The partners' privacy notices are not supplied here, so this card cannot say how those partners use information

Sharing & Disclosure · Company practice

Sharing every collected category with marketing, advertising and analytics providers

Starbucks may share each of the categories of information described in the "Information We Collect" section with marketing, advertising and analytics providers to deliver advertising to you on Starbucks' behalf. This includes counting ad impressions, creating ad audiences, and conducting personalized advertising based on your interactions with Starbucks services and on your activity on third-party services.

Supporting quotations

We may share each of the categories of information described above (in the “Information We Collect” section) with marketing, advertising and analytics providers to deliver advertising to you on behalf of Starbucks, including counting ad impressions, creating ad audiences, and conducting personalized advertising based on your interactions with our services as well as your activity on third-party services.

Qualifications & exceptions

  • Worded "may share"
  • Applies to "each of the categories of information" in section 2
  • Purposes named: counting impressions, creating audiences, personalized advertising across Starbucks and third-party services

Not stated here

  • Section 13(b) separately says that sharing certain identifiers, device activity information, transaction information and inferences with some advertising partners may be deemed a "sale" or "sharing" for targeted advertising, and gives an opt-out; this section does not mention that opt-out

Cross-references

  • contrast (model-proposed): Opt out of sale or sharing for targeted advertising: Cookie Preferences, preference signals, Do Not Sell or Share link — contrast: Section 5 says each category of collected information may be shared with advertising and analytics providers. Section 13(b) describes the sale or sharing that may be deemed "sale" or "sharing" for targeted advertising as involving certain identifiers, device activity information, transaction information and inferences, and offers an opt-out for that. The Notice does not say whether the opt-out reaches every category section 5 lists.

Sharing & Disclosure · Company practice

Sharing in a merger or transfer of business assets

If Starbucks becomes involved in a merger, corporate transaction or another situation involving the transfer of some or all of its business assets, it may share your information with the business entities or people involved in the negotiation or transfer.

Supporting quotations

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.

Qualifications & exceptions

  • Applies if Starbucks is involved in a merger, corporate transaction or transfer of business assets

Not stated here

  • The Notice does not say whether you would be told or could object

Sharing & Disclosure · Company practice

Content you share publicly may be seen by others, and Starbucks is not responsible for what you post

Starbucks displays content and information that you share publicly or permit or authorize it to share publicly, such as reviews. If you post information on a blog or another part of its websites, other visitors may see it. Starbucks says it is not responsible for the information you choose to submit in these public areas.

Supporting quotations

We display content and information that you share publicly or permit or authorize us to share publicly, such as reviews.
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.

Qualifications & exceptions

  • Applies to content you share publicly or permit Starbucks to share publicly
  • Starbucks disclaims responsibility for what you submit in public areas

Sharing & Disclosure · Company commitment

No knowing sale or sharing of under-18 customers' information for targeted advertising

Starbucks says it does not knowingly sell or share the information of its customers under the age of 18 for targeted advertising.

Supporting quotations

Additionally, we do not knowingly sell or share information of our customers under the age of 18 for targeted advertising.

Qualifications & exceptions

  • Worded "do not knowingly": limited to what Starbucks knows
  • Limited to "sell or share" for targeted advertising; the sentence does not address other uses of under-18 customers' information

Cross-references

Sharing & Disclosure · Company practice

Linked third-party sites and apps are governed by their own policies, not Starbucks

Starbucks' websites and apps may offer links to websites and apps run by third parties. Starbucks tells you to read the privacy notice, terms and conditions and other policies of any linked site you visit, says it is not responsible for third parties' policies and practices, and says information you give those organizations is governed by their own notices, terms and policies.

Supporting quotations

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.
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.

Qualifications & exceptions

  • Applies to links to sites and apps operated by third parties, not by Starbucks
  • Starbucks disclaims responsibility for third parties' policies and practices

Not stated here

  • The third parties' policies are not supplied here, so this card cannot say what they provide

Sharing & Disclosure · User right or choice

Opt out of sale or sharing for targeted advertising: Cookie Preferences, preference signals, Do Not Sell or Share link

Starbucks says it does not sell your personal information for money, but sharing some information with some advertising partners (certain identifiers, internet or device activity information, transaction information, and inferences about your use of the Services) may be deemed a "sale" or "sharing" for targeted advertising under privacy laws. You may have the right to opt out. For sale or sharing that happens through cookies and similar technologies on its website, you use the Cookie Preferences link at the bottom of the website; you may need to repeat your selections on each device and browser, and again if you clear cookies or reset the browser. Starbucks says it will honor browser opt-out preference signals. For sale or sharing that does not happen through cookies or similar technologies on the website, you submit a request through the "Do Not Sell or Share My Personal Information" link.

Supporting quotations

Although we do not sell your personal information for money, our sharing of your personal information with some advertising partners (including certain identifiers, internet or other network or device activity information, transaction information, and inferences about your use of Starbucks Services) may be deemed a “sale” or “sharing” for targeted advertising purposes under applicable privacy laws.
You may have the right to opt-out of your personal information being sold or shared for purposes of targeted advertising.
You may exercise this right with respect to such selling or sharing that takes place via cookies and similar technologies on this website by managing your preferences using the Cookie Preferences link at the bottom of the website.
(You may need to repeat the Cookies Preference selections from each device and browser that you use in connection with Starbucks Services, as well as in a particular browser or device if you clear cookies or reset the browser.)
We will honor such opt-out preference signals.
To opt out of the sale or sharing of personal information for targeted advertising that does not take place via cookies or similar technologies on this website, please submit an opt-out request using the “Do Not Sell or Share My Personal Information” link.

Qualifications & exceptions

  • Worded "may have the right"; depends on applicable law
  • The Cookie Preferences route covers only sale or sharing "via cookies and similar technologies on this website", and must be repeated per device and browser
  • Starbucks says it will honor opt-out preference signals sent by a browser
  • The categories named here are a subset; section 5 says each category of information may be shared with advertising and analytics providers

Not stated here

  • The Notice does not say whether the opt-out covers every category of information section 5 lists for advertising and analytics providers

Sharing & Disclosure · User right or choice

California residents: no disclosure to third parties for their direct marketing if you have opted out

If you are a California resident, Starbucks says it will not disclose your personal information to third parties for those third parties' direct marketing purposes, if you have exercised your option to prevent such disclosures. To make that request you use the "Do Not Sell or Share My Personal Information" link.

Supporting quotations

(c) Additional California Rights
If you are a California resident, we will not disclose your personal information to third parties for the third parties’ direct marketing purposes, if you have exercised your option to prevent such disclosures.
To request such option, please submit your request using the “Do Not Sell or Share My Personal Information” link.

Qualifications & exceptions

  • Region: California residents
  • Applies only "if you have exercised your option to prevent such disclosures"

Cross-references

Sharing & Disclosure · Company commitment

Framework onward transfers: Starbucks stays liable for its agents unless it proves it is not responsible

For onward transfers of personal data from the EU, the U.K. and Switzerland, Starbucks Corporation says it complies with the Data Privacy Framework Principles, including the onward transfer liability provisions. It says it is accountable for personal data it receives under the frameworks and then transfers to a third party acting as its agent. It remains liable under the Principles if that agent processes personal information in a way inconsistent with them, unless Starbucks Corporation proves it is not responsible for the event giving rise to damage.

Supporting quotations

Starbucks Corporation is accountable for the processing of personal data it receives
subsequently transfers to a third party acting as an agent on its behalf
unless Starbucks Corporation proves that it is not responsible for the event giving rise to damage
Starbucks Corporation complies with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF Principles for all onward transfers of personal data from the EU, the UK, and Switzerland, including the onward transfer liability provisions.

Qualifications & exceptions

  • Applies to onward transfers to third parties acting as agents on Starbucks' behalf
  • Liability is subject to Starbucks Corporation proving it is not responsible for the event giving rise to damage

Not stated here

  • The Principles themselves are not supplied here