We collect, use and are responsible for certain Personal Data about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that Personal Data for the purposes of those laws.
Personal Data means any information that can be used to personally identify you or contact you online or elsewhere.
We may collect and use the following Personal Data about you:
This Personal Data is required to provide products and Digital Services to you. If you do not provide Personal Data we ask for, it may delay or prevent us from providing products or services to you.
Personal Data we collect from you:
We collect most of this Personal Data directly from you—in person, by telephone, text or email and/or via our website and apps. This usually occurs when you take part in one of our promotional activities or subscribe to one of our Digital Services, for example:
The type and amount of information we collect for the features listed above will vary and depends on the activity.
Personal Data we collect from other sources
We may also collect information:
We may occasionally purchase the contact details of people who might be interested in hearing from us. Before purchasing such information, we will check the wording used when your information was originally collected, to make sure that we only contact people who have actively expressed an interest in receiving information from third parties.
We may also receive information if you have provided permission to other organisations to share it with us. Before providing permission to such third party organisations to share your personal information, you should check their privacy notices carefully. Subject to applicable laws, we may use a variety of technologies that collect and provide information about how our Digital Services are accessed and used by you. We may also use demographic information about who uses our Digital Services, which we get from third parties such as Google or social media that you use (we call this “Usage Information”).
Usage Information may consist of the pages you have visited, the time you visited them and which beverage information (or other content) you accessed or provided. It also includes which language you use, demographic information about you (such as your age, gender and interest areas, where available) and which pages you have visited before you visited the current page.
How and why do we use tracking technologies?
We use tracking technologies such as cookies, IP address recording or log files, to gather technical information such as your web browser type and which operating system you use, the webpage you came from, your path through our website and your Internet Service Provider. This is so we can improve the functionality of our websites and better understand how visitors like you use our Digital Services and the tools they offer.
Often, individuals will interact with us in multiple ways and will provide us with personal information in different contexts. We may use your personal information to obtain a profile of your different interactions with us and to understand your preferences.
These tracking technologies help us tailor our Digital Services to your personal needs:
Under data protection law, we can only use your Personal Data if we have a proper reason for doing so, e.g.:
When you submit your Personal Data, you may also be given the option (through a tick box or other consent mechanism) to have your information used for an activity or service different from the one you are requesting. For example, if you enter a contest to win a prize, you may also be invited to sign up for a newsletter about other products. If you choose to have your information used for another activity or service in this way we will use your information to provide them to you.
In addition, when you submit your Personal Data, you may be given the option (through a tick box or other consent mechanism) for your information to be used for other Pernod Ricard products. If you choose this option we (and other Pernod Ricard Group affiliates) will use your information to provide you with information and promotions regarding other Pernod Ricard products.
We may also use your email address to send you transactional or administrative communications such as confirmation emails when you sign up for, or unsubscribe from, a specific registration or activity. We may also use it for certain service-related announcements, such as updates to our Privacy Notice, discontinued features or programs on our Digital Services, changes to our online services or technical support policies.
We retain your personal data in our global consumer database which allows us to ensure that your Personal Data remains accurate and up to date and to share your Personal Data with appropriate Pernod Ricard group affiliates. To avoid duplication in our database, we may use information about each of your interactions with one of our Pernod Ricard Group affiliates to check whether your Personal Data is still accurate. We will use that information to complete, enhance or update your Personal Data with the additional information you might have provided.
Subject to applicable laws, this may include occasionally combining, updating, or otherwise enhancing the Personal Data collected through our Digital Services with anonymised data we get from outside records or third parties. For instance, we may combine purely demographic or survey information (e.g., age, gender, household information, and other interests) not linked to any personal information about you with Personal Data collected in other cases (such as during account registration).
We may also use your Personal Data, the combined information referred to above and/or demographic information for our internal marketing, segmentation, analysis and demographic studies. This helps us to constantly improve, personalise, and customise the products and services we provide.
Legitimate interests – managing our business
In relation to a number of uses of Personal Data we refer to above we are doing this on the basis that it is in our legitimate interests – or those of a third party – for us to do so. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. These interests cover a number of aspects of our business operations, namely:
We may use your Personal Data to send you updates (by email, text message, telephone or post) about our products and Digital Services, including exclusive offers, promotions or new products and Digital Services.
We have a legitimate interest in processing your Personal Data for promotional purposes. This means we do not always need your consent to carry out promotional activities. However, where consent is needed, we will ask for this consent separately and clearly.
You have the right to opt out of receiving promotional communications at any time by:
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or Digital Services in the future, or if there are changes in the law, regulation, or the structure of our business.
If you choose not to submit any Personal Data when requested, you may not be able to participate in certain activities or use some of the personalised features of our Digital Services. This may also limit the services and special offers we can provide you. For example, if you refuse to share your email address, you will not be able to receive any of our newsletters or otherwise register for our Digital Services. However, you do not need to give us any Personal Data to simply browse our websites and learn more about us and our products.
We will never share your Personal Data with any third party that intends to use it for direct marketing purposes, unless we have specifically told you and you have given us explicit permission to do this.
We may also share your Personal Data with other third parties, but only in the following circumstances:
We and our affiliates in the Pernod Ricard Group are a global group and your Personal Data may be transferred across international borders. It may be transferred to countries that have different data protection laws to the country from where you submitted your Personal Data. Your Personal Data may also be transferred between different companies of the Pernod Ricard Group located in different countries.
We will, however, ensure the transfer complies with data protection law both during transit and at the storage location and all Personal Data will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. You can check here for a list of countries where we have an affiliate within the Pernod Ricard Group that may receive your Personal Data.
Our main service providers for the operation of our Digital Media are based in the United States. The transfers of personal data to these services providers are implemented in accordance with applicable laws and rely on standard contractual clauses as set out by the European Commission. Such service providers are also bound by a contract that ensures a high standard of privacy protection and requires (amongst other provisions) that they act only on a member of Pernod Ricard Group’s instructions and implement technical measures necessary on an ongoing basis to keep your Personal Data secure.
We may store the Personal Data that you send to us via our Digital Services in our databases. We will not retain your Personal Data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of Personal Data.
We retain your Personal Data as long as your account is active, for the duration of a contract with you or however long it takes to provide you with the products or services requested, to answer queries or resolve problems, to show that we treated you fairly, to keep records required by law and to improve or offer new services.
We may also need to retain your Personal Data to comply with our legal and regulatory obligations, resolve disputes, enforce our agreements, and similar records management purposes.
We may also retain your Personal Data for a reasonable period after you stop using our services or our Digital Services. After this period, your Personal Data will be deleted from all systems in the Pernod Ricard Group.
If you ask us to delete your information in accordance with your rights set out in Article 9 below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future.
We have appropriate security measures to prevent your Personal Data from being accidentally lost, or used or accessed unlawfully. These include: (i) storing your Personal Data in secure operating environments that are not available to the public and that are only accessible to authorised employees, our agents and contractors; and, (ii) verifying the identities of registered users before they can access Personal Data we store about them.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
You have the following rights, which you can exercise free of charge:
You can ask us to:
You can object:
If your Personal Data has been processed on the basis of your consent, you can withdraw your consent at any time. We hope that we can resolve any query or concern you may raise about our use of your information. You also have the right to complain to the supervisory authority in the European Union where you work, normally live or where any alleged infringement of data protection laws occurred.
If you would like to exercise your right to object to direct marketing please email us on firstname.lastname@example.org.
If you would like to exercise any of your other rights, please email us on email@example.com.
Your objection (or withdrawal of consent) may mean we cannot provide the products or services you have requested of us or you may not be able to use the services we offer. We will advise you where this is the case. In certain circumstances even if you withdraw your consent we may still be able to process your Personal Data if required or permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and regulatory obligations.
Our Digital Services may contain links that will direct you to other websites or services that are operated and controlled by third parties. This includes links from advertisers, sponsors and partners that may use our brands or logo(s) as part of a co-branding agreement.
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