Privacy Policy

Chivas Brothers Limited respects your right to privacy when you use our websites (including www.ballantines.com), our mobile applications, our pages on social networks, web forms and whenever else you communicate electronically with us (our “Digital Services”). That’s why we’ve developed this Privacy Policy to explain how Chivas Brothers Limited (“Chivas”, “we,” or “our”) collects, stores, uses and processes the personal information you share with us through our Digital Services.

Before using our Digital Services, please read this Privacy Policy carefully (including our Cookie Policy, [insert link to Cookie Policy]). If you do not agree to this Privacy Policy or the Cookies Policy, please do not use our Digital Services.

We reserve the right to make changes at any time and we will notify you of changes via email and by updating this Privacy Policy or the Cookies Policy. You should regularly review these policies to make sure you are aware of any changes which affect how your information may be used.

For Data Protection purposes, Chivas Brothers Limited is the Data Controller of any personal information you submit to www.ballantines.com (the “Website”) and related Digital Services.

  1. What personal information do we gather about you and how?

Personal information, in the context of this Privacy Policy, means any information that can be used to personally identify you or contact you online or elsewhere. This information includes data such as your name, postal address, e-mail address, phone number, (“Personally Identifiable Information”) demographic information such as your date of birth, age, gender, and your habits or preferences when they are linked to your Personally Identifiable Information (collectively called “Personal Information”). Personal Information is only collected with your informed knowledge i.e. when you knowingly submit it to us. This usually occurs when you take part in one of our promotional activities or subscribe to one of our Digital Services, for example:

• Registration or sign-up online: e.g. subscribing to a newsletter for our Digital Services or creating an account to be a member; • ‘Contacting us’ via our Digital Services;
• ‘Send to a friend’ marketing communications; • Sweepstake and contest; • Joining a loyalty program; • Buying products or services online; • Using a QR Code displayed on BALLENTINE’S products; • Events (invitation form or online forms on tablets filled out by our hostesses); • Feedback, questions, or comments through a ‘contact us’ form; • Any other request that requires the submission of Personal Information.

The type and amount of information we collect for the features listed above depends on the activity, and the Personal Information we collect may include: first and last name, email address, home address and telephone number (work or home). For some activities, you might be asked to create a username and/or password and/or to provide additional information, including: (i) your age or date of birth, (ii) gender, (iii) frequency of use, (iv) facts about your household, lifestyle, interests and/or, (v) other information relevant to you. 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 (“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.

We collect this information to gain a better idea of how people interact with our brands and our Digital Services so we can then tailor and improve them accordingly. Most Usage Information that we collect can't be linked to you individually, but if we can link it to you, then this Privacy Policy will apply.

  1. 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.

These tracking technologies help us tailor our Digital Services to your personal needs: • Subject to your consent where required by applicable law, our Digital Services use cookies and similar technologies (“cookies”). Cookies are small files placed on your device which serve a number of purposes, such as remembering your preferences. Cookies let you enjoy a richer experience, as well as help accurately measure your behavior on our website. You can learn more about which cookies we use and how to disable them in our [INSERT LINK TO COOKIES POLICY]; • An IP address is a number used on a network to identify your computer every time you connect to the Internet. We may keep track of IP addresses to (among other things): (i) troubleshoot technical issues, (ii) maintain website safety and security, (iii) restrict access to our Digital Services to certain users, and, (iv) better understand how our Digital Services are utilised; • We (or a third party on our behalf) may collect information in the form of logs files that record activity and gather statistics about browsing habits. These entries are generated anonymously, and help us gather (among other things) (i) your web browser type and operating system, (ii) information about your session (such as the URL you came from, the date and time you visited our Digital Services, and which pages you have viewed and for how long), and, (iii) other similar navigational or click-stream data. We also use log file information for our internal marketing and demographic studies, so we can constantly improve and customise the online services we offer you. Log files are only used internally, and are not associated with any personally identifiable individual.

  1. For what purpose do we use your personal information?

Generally, the information we collect is only used for any purpose for which you submitted it to us, for any purpose made clear to you at the point it was collected or here in this Privacy Policy.

These may include: • When you register or sign-up via our Digital Services: the Personal Information you give is used to provide you with the benefits that typically come along with registration. This includes the ability to receive communications you select at the time of registration or that automatically come with your registration. For example, subscription to a newsletter, creation of an account, participation in a sweepstake or contest, invitation to or attendance at an event organised by BALLENTINE’S; • When you use the ‘Send to a friend’ feature: Personal Information for one-time use (typically, names and email addresses) is used only once (e.g., to send a message) and is not retained by us; • When using e-commerce on some of our websites: we use your Personal Information to manage your order and deliver your products (or a third party on our behalf); • When you use a QR Code displayed on CBL products: we use your Personal Information to send you more information on the products where the QR code was displayed or other products; • When you submit Personal Information on the iPads or other mobile devices available in our Heritage Centers or distilleries: this is used to send you more information on the products; • Feedback, questions, or comments through our ‘Contact Us’ form and our ‘Tell Us’ compliance reporting system: if you contact us via an online contact form, your information is used to respond to your inquiry or comment.

When you submit your Personal Information, you may also be given the option (through a tick box or otherwise) 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 our products or Pernod Ricard Group 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.

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 Policy, discontinued features or programs on our Digital Services, changes to our online services or technical support policies. Collectively, these communications are referred to in this Privacy Policy as “Non Transactional Communications”.

We may also use your personal and/or demographic information for our internal marketing and demographic studies. This helps us constantly improve, personalise, and customise the products and services we provide.

Subject to applicable laws, this may include combining, updating, or otherwise enhancing the Personal Information collected through our Digital Services with anonymised data we get from outside records or third parties.

  1. What happens if you do not wish to share your personal information with us?

If you choose not to submit any Personal Information 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 don’t 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 Information to simply browse our websites and learn more about BALLENTINE’S, Chivas and our products.

  1. Who do we disclose your personal information to and why?

Except as expressly set out in this Privacy Policy, we will never share your Personal Information 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 share your personal information with our subsidiary companies, or companies within the Pernod Ricard SA group of companies listed at the end of this Privacy Policy (collectively referred to as the “Pernod Ricard Group”) for the purposes explained in Article 3 or as set out in this Privacy Policy.

We may also share your Personal Information with third parties, but only in the following circumstances: • We may use service providers, agents or contractors 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 it. Any such third party must provide the same levels of security for your Personal Information as us and, where required, are bound by a legal agreement to keep your Personal Information 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 Information and share it with that partner or sponsor as part of the event. If your Personal Information is being collected by (or is shared with) a company other than us as part of any such promotion, we will let you know at the time it is collected;

When we run a promotion with another company, we may provide a separate link to that company's privacy policy which you should read before you share any Personal Information, because we cannot guarantee they adhere to the same privacy practices. If you do not want your information to be collected by or shared with a company other than us, you can choose not to opt in or participate in these events at the time the Personal Information is collected or requested;

• We may also disclose your Personal Information if we are required to do so by law, or if (in good faith) such action is necessary to comply with legal processes, to respond to any claims, or to protect the safety or rights of Chivas, its customers, or the public; • In the event of a merger or acquisition of all or part of Chivas by another company, or in the event that Chivas were to sell or dispose of all or a part of its business. In this case the acquirer would have access to the information maintained by us, which could include Personal Information, subject to applicable law. Similarly, Personal Information 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; • We may share aggregated demographic or survey information with third parties, but this information is in anonymous form and does not contain any Personal Information. The aggregate information that we share may include anonymous information that is captured through the use of cookies and other similar tracking technology, as explained in Article 2.

  1. Is your personal information sent to recipients located in other countries and why?

We are part of a global company and your Personal Information 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 Information. Your Personal Information may also be transferred between different companies of the Pernod Ricard Group located in different countries.

We take appropriate steps to maintain the security of Personal Information both during transit and at the storage location by implementing contractual clauses which comply with applicable laws. You can check the Annex for a list of countries where we have an affiliate likely to receive your Personal Information.

Our main service providers are bound by a contract that ensures a high standard of privacy protection and requires (amongst other provisions) that they act only on our instructions and implement and maintain every technical measure necessary to keep your Personal Information secure.

  1. How long do we keep your personal information?

We may store the Personal Information that you send to us via our Digital Services in our databases. We retain your Personal Information 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 services requested, to answer queries or resolve problems and to improve or offer new services.

We may also need to retain your Personal Information for a reasonable period of time to comply with our legal and regulatory obligations, resolve disputes, enforce our agreements, and similar records management purposes.

We may also retain your Personal Information for a reasonable period after you stop using our services or our Digital Services. After this period, your Personal Information will be deleted from all systems in the Pernod Ricard Group.

If you ask us to no longer use your Personal Information to provide you with services, for example by opting-out of marketing emails, please contact us as described in Article 9. We remind you that you also have a right to have your Personal Information deleted at any time. This is also described in Article 9.

  1. How do we keep your personal information secure?

We take all necessary technical and organisational measures to protect the confidentiality and security of your Personal Information collected from our Digital Services, including sensitive Personal Information.

These efforts include, but are not necessarily limited to: (i) storing your Personal Information in secure operating environments that are not available to the public and that are only accessible to authorised Chivas employees, our agents and contractors; and, (ii) verifying the identities of registered users before they can access Personal Information we store about them.

  1. How you can you access, modify, delete or object to the use of your personal information?

You can access any Personal Information we hold about you by contacting us at Ballantines@pernod-ricard.com

We can also help you with the following issues: • Corrections to your Personal Information if it is inaccurate, incomplete or out of date or request the deletion of your Personal Information. • You reserve the right to not share any of your Personal Information with us or object to the processing of your data by us for legitimate reasons. However, if you choose this option, you will be limited in the activities and features we can provide you with. • If you do not want to receive newsletters, announcements, or other communications and/or services from us, please do not opt-in for those communications or services when you first register. If you have already opted-in and later want to opt-out, please click on the unsubscribe link in our communications or email us at Ballantines@pernod-ricard.com

• Along with every email message sent to you, we provide you with the opportunity to discontinue receiving communications in the future (i.e., unsubscribe). Simply follow the unsubscribe process or instructions provided in the email. If you participated in a program that involved a third party and you agreed to receive communications from that third party, you will need to contact them directly to opt-out. This process should be outlined in the third party’s own privacy policy.

  1. How do we treat children's information?

Our Digital Services are not intended for children under the age of majority (“Minor”), so we do not knowingly collect Personal Information from Minors. You must be at least eighteen years old to create an account and engage in activities and transactions on our Digital Services. By creating an account or engaging in activities or transactions, you confirm that you are at least eighteen years old and are fully able to enter into, comply with and be legally bound by our any terms of use made available to you and this Privacy Policy. If we are notified or learn that a Minor has submitted personal data to us through our Digital Services, we will delete their Personal Information.

  1. 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 logo(s) as part of a co-branding agreement.

We have no control over these third parties, and your use of their websites and features are subject to the privacy policies posted on those websites. We are not responsible or liable for the privacy practices or business practices of any third-party website. Therefore, you should exercise caution and review the privacy policies applicable to those external websites you visit them, before you provide your Personal Information.

  1. How can you contact us?

If you have any questions, complaints, or comments about this Privacy Policy or our how we collect and manage your Personal Information, please contact us in writing at c/o Data Protection Officer, Chivas Brothers Limited, Chivas House, 72 Chancellors Road, London, W6 9RS, or sending an email to: Ballantines@pernod-ricard.com

Last updated: March 2017 2016

Annex: Pernod Ricard Group

This is a non-exhaustive list of the Pernod Ricard market companies that are referenced in this Privacy Policy:

AMERICAS: Casa Pedro Domecq (Mexico), Corby Spirit & Wine Limited (Canada), Havana Club International (Cuba), Pernod Ricard Andes (Chile, Ecuador, Bolivia, Peru), Pernod Ricard Argentina, Pernod Ricard Brazil, Pernod Ricard Caribbean, Pernod Ricard Central Americas, Pernod Ricard Colombia, Pernod Ricard Dominican Republic, Pernod Ricard Uruguay, Pernod Ricard USA, Pernod Ricard USA Travel Retail and Pernod Ricard Venezuela.

ASIA & OCEANIA: Pernod Ricard Asia, Pernod Ricard Asia Duty Free, Pernod Ricard Australia, Pernod Ricard China, Pernod Ricard Hong Kong Ltd, Pernod Ricard India, Pernod Ricard Indonesia, Pernod Ricard Japan, Pernod Ricard Korea, Pernod Ricard Malaysia, Pernod Ricard Pacific Travel Retail, Pernod Ricard New Zealand, Pernod Ricard Philippines, Pernod Ricard Singapore, Pernod Ricard Taiwan, Pernod Ricard Thailand, and Pernod Ricard Vietnam.

EUROPE: Dillon Bass (Northern Ireland), Domecq Bodegas, S.L.U., Georgian Wine & Spirits (Georgia), Irish Distillers Pernod Ricard (Ireland), Jan Becher (Czech Republic), Pernod (France), Pernod Ricard Travel Retail Europe, Pernod Ricard Armenia, Pernod Ricard Austria, Pernod Ricard Baltics, Pernod Ricard Belgium, Pernod Ricard Bosnia & Herzegovina, Pernod Ricard Bulgaria, Pernod Ricard Canarias SL, Pernod Ricard Croatia, Pernod Ricard Denmark, Pernod Ricard Deutschland, Pernod Ricard Espana, Pernod Ricard Estonia, Pernod Ricard Europe S.A., Pernod Ricard Finland, Pernod Ricard Hellas (Greece), Pernod Ricard Hungary, Pernod Ricard Italia, Pernod Ricard Kazakhstan, Pernod Ricard Latvia, Pernod Ricard Lietuva, Pernod Ricard Lithuania, Pernod Ricard Minsk, Pernod Ricard Nederland, Pernod Ricard Norway, Pernod Ricard Polska (Poland), Pernod Ricard Portugal, Pernod Ricard Romania, Pernod Ricard Rouss (Russia), Pernod Ricard S.A., Pernod Ricard Serbia, Pernod Ricard Slovenia, Pernod Ricard Sweden, Pernod Ricard Swiss, Pernod Ricard Turkey, Pernod Ricard Ukraine, Pernod Ricard United Kingdom, Ricard (France), World Brands Duty Free Limited, Wyborwa SA (Poland), Yerevan Brandy Company (Armenia).

MIDDLE EAST & AFRICA: Pernod Ricard Angola, Pernod Ricard Gulf, Pernod Ricard Kenya, Pernod Ricard Middle East and North Africa, Pernod Ricard Morocco, Pernod Ricard Namibia, Pernod Ricard Nigeria, Pernod Ricard Sub-Saharan Africa and Pernod Ricard South Africa.

Privacy Policy

Chivas Brothers Limited respects your right to privacy when you use our websites (including www.ballantines.com), our mobile applications, our pages on social networks, web forms and whenever else you communicate electronically with us (our “Digital Services”). That’s why we’ve developed this Privacy Policy to explain how Chivas Brothers Limited (“Chivas”, “we,” or “our”) collects, stores, uses and processes the personal information you share with us through our Digital Services.

Before using our Digital Services, please read this Privacy Policy carefully (including our Cookie Policy, [insert link to Cookie Policy]). If you do not agree to this Privacy Policy or the Cookies Policy, please do not use our Digital Services.

We reserve the right to make changes at any time and we will notify you of changes via email and by updating this Privacy Policy or the Cookies Policy. You should regularly review these policies to make sure you are aware of any changes which affect how your information may be used.

For Data Protection purposes, Chivas Brothers Limited is the Data Controller of any personal information you submit to www.ballantines.com (the “Website”) and related Digital Services.

  1. What personal information do we gather about you and how?

Personal information, in the context of this Privacy Policy, means any information that can be used to personally identify you or contact you online or elsewhere. This information includes data such as your name, postal address, e-mail address, phone number, (“Personally Identifiable Information”) demographic information such as your date of birth, age, gender, and your habits or preferences when they are linked to your Personally Identifiable Information (collectively called “Personal Information”). Personal Information is only collected with your informed knowledge i.e. when you knowingly submit it to us. This usually occurs when you take part in one of our promotional activities or subscribe to one of our Digital Services, for example:

• Registration or sign-up online: e.g. subscribing to a newsletter for our Digital Services or creating an account to be a member; • ‘Contacting us’ via our Digital Services;
• ‘Send to a friend’ marketing communications; • Sweepstake and contest; • Joining a loyalty program; • Buying products or services online; • Using a QR Code displayed on BALLENTINE’S products; • Events (invitation form or online forms on tablets filled out by our hostesses); • Feedback, questions, or comments through a ‘contact us’ form; • Any other request that requires the submission of Personal Information.

The type and amount of information we collect for the features listed above depends on the activity, and the Personal Information we collect may include: first and last name, email address, home address and telephone number (work or home). For some activities, you might be asked to create a username and/or password and/or to provide additional information, including: (i) your age or date of birth, (ii) gender, (iii) frequency of use, (iv) facts about your household, lifestyle, interests and/or, (v) other information relevant to you. 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 (“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.

We collect this information to gain a better idea of how people interact with our brands and our Digital Services so we can then tailor and improve them accordingly. Most Usage Information that we collect can't be linked to you individually, but if we can link it to you, then this Privacy Policy will apply.

  1. 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.

These tracking technologies help us tailor our Digital Services to your personal needs: • Subject to your consent where required by applicable law, our Digital Services use cookies and similar technologies (“cookies”). Cookies are small files placed on your device which serve a number of purposes, such as remembering your preferences. Cookies let you enjoy a richer experience, as well as help accurately measure your behavior on our website. You can learn more about which cookies we use and how to disable them in our [INSERT LINK TO COOKIES POLICY]; • An IP address is a number used on a network to identify your computer every time you connect to the Internet. We may keep track of IP addresses to (among other things): (i) troubleshoot technical issues, (ii) maintain website safety and security, (iii) restrict access to our Digital Services to certain users, and, (iv) better understand how our Digital Services are utilised; • We (or a third party on our behalf) may collect information in the form of logs files that record activity and gather statistics about browsing habits. These entries are generated anonymously, and help us gather (among other things) (i) your web browser type and operating system, (ii) information about your session (such as the URL you came from, the date and time you visited our Digital Services, and which pages you have viewed and for how long), and, (iii) other similar navigational or click-stream data. We also use log file information for our internal marketing and demographic studies, so we can constantly improve and customise the online services we offer you. Log files are only used internally, and are not associated with any personally identifiable individual.

  1. For what purpose do we use your personal information?

Generally, the information we collect is only used for any purpose for which you submitted it to us, for any purpose made clear to you at the point it was collected or here in this Privacy Policy.

These may include: • When you register or sign-up via our Digital Services: the Personal Information you give is used to provide you with the benefits that typically come along with registration. This includes the ability to receive communications you select at the time of registration or that automatically come with your registration. For example, subscription to a newsletter, creation of an account, participation in a sweepstake or contest, invitation to or attendance at an event organised by BALLENTINE’S; • When you use the ‘Send to a friend’ feature: Personal Information for one-time use (typically, names and email addresses) is used only once (e.g., to send a message) and is not retained by us; • When using e-commerce on some of our websites: we use your Personal Information to manage your order and deliver your products (or a third party on our behalf); • When you use a QR Code displayed on CBL products: we use your Personal Information to send you more information on the products where the QR code was displayed or other products; • When you submit Personal Information on the iPads or other mobile devices available in our Heritage Centers or distilleries: this is used to send you more information on the products; • Feedback, questions, or comments through our ‘Contact Us’ form and our ‘Tell Us’ compliance reporting system: if you contact us via an online contact form, your information is used to respond to your inquiry or comment.

When you submit your Personal Information, you may also be given the option (through a tick box or otherwise) 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 our products or Pernod Ricard Group 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.

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 Policy, discontinued features or programs on our Digital Services, changes to our online services or technical support policies. Collectively, these communications are referred to in this Privacy Policy as “Non Transactional Communications”.

We may also use your personal and/or demographic information for our internal marketing and demographic studies. This helps us constantly improve, personalise, and customise the products and services we provide.

Subject to applicable laws, this may include combining, updating, or otherwise enhancing the Personal Information collected through our Digital Services with anonymised data we get from outside records or third parties.

  1. What happens if you do not wish to share your personal information with us?

If you choose not to submit any Personal Information 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 don’t 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 Information to simply browse our websites and learn more about BALLENTINE’S, Chivas and our products.

  1. Who do we disclose your personal information to and why?

Except as expressly set out in this Privacy Policy, we will never share your Personal Information 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 share your personal information with our subsidiary companies, or companies within the Pernod Ricard SA group of companies listed at the end of this Privacy Policy (collectively referred to as the “Pernod Ricard Group”) for the purposes explained in Article 3 or as set out in this Privacy Policy.

We may also share your Personal Information with third parties, but only in the following circumstances: • We may use service providers, agents or contractors 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 it. Any such third party must provide the same levels of security for your Personal Information as us and, where required, are bound by a legal agreement to keep your Personal Information 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 Information and share it with that partner or sponsor as part of the event. If your Personal Information is being collected by (or is shared with) a company other than us as part of any such promotion, we will let you know at the time it is collected;

When we run a promotion with another company, we may provide a separate link to that company's privacy policy which you should read before you share any Personal Information, because we cannot guarantee they adhere to the same privacy practices. If you do not want your information to be collected by or shared with a company other than us, you can choose not to opt in or participate in these events at the time the Personal Information is collected or requested;

• We may also disclose your Personal Information if we are required to do so by law, or if (in good faith) such action is necessary to comply with legal processes, to respond to any claims, or to protect the safety or rights of Chivas, its customers, or the public; • In the event of a merger or acquisition of all or part of Chivas by another company, or in the event that Chivas were to sell or dispose of all or a part of its business. In this case the acquirer would have access to the information maintained by us, which could include Personal Information, subject to applicable law. Similarly, Personal Information 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; • We may share aggregated demographic or survey information with third parties, but this information is in anonymous form and does not contain any Personal Information. The aggregate information that we share may include anonymous information that is captured through the use of cookies and other similar tracking technology, as explained in Article 2.

  1. Is your personal information sent to recipients located in other countries and why?

We are part of a global company and your Personal Information 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 Information. Your Personal Information may also be transferred between different companies of the Pernod Ricard Group located in different countries.

We take appropriate steps to maintain the security of Personal Information both during transit and at the storage location by implementing contractual clauses which comply with applicable laws. You can check the Annex for a list of countries where we have an affiliate likely to receive your Personal Information.

Our main service providers are bound by a contract that ensures a high standard of privacy protection and requires (amongst other provisions) that they act only on our instructions and implement and maintain every technical measure necessary to keep your Personal Information secure.

  1. How long do we keep your personal information?

We may store the Personal Information that you send to us via our Digital Services in our databases. We retain your Personal Information 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 services requested, to answer queries or resolve problems and to improve or offer new services.

We may also need to retain your Personal Information for a reasonable period of time to comply with our legal and regulatory obligations, resolve disputes, enforce our agreements, and similar records management purposes.

We may also retain your Personal Information for a reasonable period after you stop using our services or our Digital Services. After this period, your Personal Information will be deleted from all systems in the Pernod Ricard Group.

If you ask us to no longer use your Personal Information to provide you with services, for example by opting-out of marketing emails, please contact us as described in Article 9. We remind you that you also have a right to have your Personal Information deleted at any time. This is also described in Article 9.

  1. How do we keep your personal information secure?

We take all necessary technical and organisational measures to protect the confidentiality and security of your Personal Information collected from our Digital Services, including sensitive Personal Information.

These efforts include, but are not necessarily limited to: (i) storing your Personal Information in secure operating environments that are not available to the public and that are only accessible to authorised Chivas employees, our agents and contractors; and, (ii) verifying the identities of registered users before they can access Personal Information we store about them.

  1. How you can you access, modify, delete or object to the use of your personal information?

You can access any Personal Information we hold about you by contacting us at Ballantines@pernod-ricard.com

We can also help you with the following issues: • Corrections to your Personal Information if it is inaccurate, incomplete or out of date or request the deletion of your Personal Information. • You reserve the right to not share any of your Personal Information with us or object to the processing of your data by us for legitimate reasons. However, if you choose this option, you will be limited in the activities and features we can provide you with. • If you do not want to receive newsletters, announcements, or other communications and/or services from us, please do not opt-in for those communications or services when you first register. If you have already opted-in and later want to opt-out, please click on the unsubscribe link in our communications or email us at Ballantines@pernod-ricard.com

• Along with every email message sent to you, we provide you with the opportunity to discontinue receiving communications in the future (i.e., unsubscribe). Simply follow the unsubscribe process or instructions provided in the email. If you participated in a program that involved a third party and you agreed to receive communications from that third party, you will need to contact them directly to opt-out. This process should be outlined in the third party’s own privacy policy.

  1. How do we treat children's information?

Our Digital Services are not intended for children under the age of majority (“Minor”), so we do not knowingly collect Personal Information from Minors. You must be at least eighteen years old to create an account and engage in activities and transactions on our Digital Services. By creating an account or engaging in activities or transactions, you confirm that you are at least eighteen years old and are fully able to enter into, comply with and be legally bound by our any terms of use made available to you and this Privacy Policy. If we are notified or learn that a Minor has submitted personal data to us through our Digital Services, we will delete their Personal Information.

  1. 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 logo(s) as part of a co-branding agreement.

We have no control over these third parties, and your use of their websites and features are subject to the privacy policies posted on those websites. We are not responsible or liable for the privacy practices or business practices of any third-party website. Therefore, you should exercise caution and review the privacy policies applicable to those external websites you visit them, before you provide your Personal Information.

  1. How can you contact us?

If you have any questions, complaints, or comments about this Privacy Policy or our how we collect and manage your Personal Information, please contact us in writing at c/o Data Protection Officer, Chivas Brothers Limited, Chivas House, 72 Chancellors Road, London, W6 9RS, or sending an email to: Ballantines@pernod-ricard.com

Last updated: March 2017 2016

Annex: Pernod Ricard Group

This is a non-exhaustive list of the Pernod Ricard market companies that are referenced in this Privacy Policy:

AMERICAS: Casa Pedro Domecq (Mexico), Corby Spirit & Wine Limited (Canada), Havana Club International (Cuba), Pernod Ricard Andes (Chile, Ecuador, Bolivia, Peru), Pernod Ricard Argentina, Pernod Ricard Brazil, Pernod Ricard Caribbean, Pernod Ricard Central Americas, Pernod Ricard Colombia, Pernod Ricard Dominican Republic, Pernod Ricard Uruguay, Pernod Ricard USA, Pernod Ricard USA Travel Retail and Pernod Ricard Venezuela.

ASIA & OCEANIA: Pernod Ricard Asia, Pernod Ricard Asia Duty Free, Pernod Ricard Australia, Pernod Ricard China, Pernod Ricard Hong Kong Ltd, Pernod Ricard India, Pernod Ricard Indonesia, Pernod Ricard Japan, Pernod Ricard Korea, Pernod Ricard Malaysia, Pernod Ricard Pacific Travel Retail, Pernod Ricard New Zealand, Pernod Ricard Philippines, Pernod Ricard Singapore, Pernod Ricard Taiwan, Pernod Ricard Thailand, and Pernod Ricard Vietnam.

EUROPE: Dillon Bass (Northern Ireland), Domecq Bodegas, S.L.U., Georgian Wine & Spirits (Georgia), Irish Distillers Pernod Ricard (Ireland), Jan Becher (Czech Republic), Pernod (France), Pernod Ricard Travel Retail Europe, Pernod Ricard Armenia, Pernod Ricard Austria, Pernod Ricard Baltics, Pernod Ricard Belgium, Pernod Ricard Bosnia & Herzegovina, Pernod Ricard Bulgaria, Pernod Ricard Canarias SL, Pernod Ricard Croatia, Pernod Ricard Denmark, Pernod Ricard Deutschland, Pernod Ricard Espana, Pernod Ricard Estonia, Pernod Ricard Europe S.A., Pernod Ricard Finland, Pernod Ricard Hellas (Greece), Pernod Ricard Hungary, Pernod Ricard Italia, Pernod Ricard Kazakhstan, Pernod Ricard Latvia, Pernod Ricard Lietuva, Pernod Ricard Lithuania, Pernod Ricard Minsk, Pernod Ricard Nederland, Pernod Ricard Norway, Pernod Ricard Polska (Poland), Pernod Ricard Portugal, Pernod Ricard Romania, Pernod Ricard Rouss (Russia), Pernod Ricard S.A., Pernod Ricard Serbia, Pernod Ricard Slovenia, Pernod Ricard Sweden, Pernod Ricard Swiss, Pernod Ricard Turkey, Pernod Ricard Ukraine, Pernod Ricard United Kingdom, Ricard (France), World Brands Duty Free Limited, Wyborwa SA (Poland), Yerevan Brandy Company (Armenia).

MIDDLE EAST & AFRICA: Pernod Ricard Angola, Pernod Ricard Gulf, Pernod Ricard Kenya, Pernod Ricard Middle East and North Africa, Pernod Ricard Morocco, Pernod Ricard Namibia, Pernod Ricard Nigeria, Pernod Ricard Sub-Saharan Africa and Pernod Ricard South Africa.