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:
• contacting us at [email protected]
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
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.
4. What happens if you do not wish to share your Personal Data with us?
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.
5. Who do we disclose your Personal Data to and why?
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 may use third parties to help deliver our products or Digital Services to you, e.g. payment service providers, warehouses and delivery companies;
• We may share your Personal Data with social media providers such as Facebook, Twitter and Instagram, in which case email addresses will be uploaded then hashed. For example, where you are a registered user of Facebook, we will use your email address in an encrypted format to enable Facebook to find other registered users of their services that share similar interests to you based on: (1) information that we observe about you from your different interactions with us; and (2) the information Facebook holds about you;
• We may share your Personal Data with third parties who provide programmatic advertising services to serve you with relevant advertising;
• We may use service providers, agents or contractors e.g. marketing and digital agencies to support the internal operation of our Digital Services, and to assist us with administering them or the various functions, programs and promotions available on them. Any such third party must provide appropriate levels of security for your Personal Data and, where required, are bound by a legal agreement to keep your Personal Data private, secure and to process it only on our specific instructions;
• When we run a joint or co-sponsored program or promotion on our Digital Services with another company, organisation, or other reputable third party, we may collect and process Personal Data and share it with that partner or sponsor as part of the event. If your Personal Data is being collected by (or is shared with) a company other than one that is part of the Pernod Ricard Group as part of any such promotion, we will let you know at the time it is collected;
• We may also disclose your Personal Data if we are required to do so by law or by law enforcement agencies or regulatory bodies, or if such action is necessary to comply with legal or regulatory processes, to respond to or pursue any claims, or to protect the safety or rights of us, our employees, customers, or the public;
• In the event of a merger or acquisition of all or part of us by another company, or in the event that we were to sell or dispose of all or a part of our business. In this case the acquirer would have access to the information maintained by us, which could include Personal Data, subject to applicable law. Similarly, Personal Data may be transferred as part of a corporate reorganisation, insolvency proceeding, or other similar event, if permitted by and done in accordance with applicable law;
6. Is your Personal Data sent to recipients located in other countries and why?
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.
7. How long do we keep your Personal Data?
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.
8. How do we keep your Personal Data secure?
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.
9. Your rights
You have the following rights, which you can exercise free of charge:
You can ask us to:
• provide a copy of your personal data (the right of access)
• correct any mistakes in your personal data
• delete your personal data—in certain situations
• restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data
• provide you with a copy of the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
You can object:
• at any time to your personal data being processed for direct marketing including profiling;
• in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests
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 [email protected]
If you would like to exercise any of your other rights, please email us on [email protected]
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.
10. How do we treat children’s information?
11. Do we link to other third party websites?
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.
12. How can you contact us?
– by writing to: Data Privacy Champion, Chivas Brothers International Limited, Kilmalid, Stirling Road, Dumbarton G82 2SS, or sending an email to: [email protected]
– or by writing to: Data Protection Officer, Pernod Ricard SA, 12 place des Etats-Unis 75783 Paris Cedex 16
This privacy notice was last updated: August 2020.