Online Privacy Policy

31 Mar. 2017

Pernod Ricard SA, a company incorporated under French law located at 12, place des Etats-Unis 75116 Paris, France; with a share capital of 411 403 467,60 €, respects your right to privacy when you use the site accessible at the address www.havana-club.com (the “Site”) and communicate electronically with us. This Privacy Policy informs you how Pernod Ricard (“Pernod Ricard”, “we,” or “our”) collects, stores, uses and processes the personal information you provide us through the Site.

Before using our Site, please read carefully this Privacy Policy (including the Cookie Policy, please see Article 2). If you do not agree to this Privacy Policy or the Cookie Policy, please do not use our Site. We reserve the right to make changes to this Privacy Policy or the Cookies Policy at any time. We will notify you such changes by posting in this Privacy Policy or the Cookies Policy. You are thus invited to regularly review this Privacy Policy and the Cookies Policy to make sure you are aware of any changes and how your information may be used.
Pernod Ricard UK Limited is the Data Controller of any personal information you submit to the Site.

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

Personal information for the purpose of this Privacy Policy means any information that can be used to personally identify you or contact you online or offline. This information include 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 such information is linked to your personally identifiable information (collectively, “personal information”). Personal information is only collected with your informed knowledge (i.e., if you knowingly provide it to us through one of the online forms available on our Site) if you wish to participate in many of the features and services our Site have to offer and which will usually take the form of:
 

  • - Registration or sign-up in our Site: e.g. subscribing to a newsletter that is specific to a Site where applicable;
    - Sweepstake and contest;
    - Organization of events (invitation form or online forms on tablets filled out by our hostesses);
    - Feedback, questions, or comments through our “Contact Us” form;
    - Any other request that requires the submission of personal information.

The types and amount of information collected for the features listed above will vary depending on the activity. The requested personal information may include: first and last name, email address, country of residence, date of birth.
Subject to applicable law requirements, we may use a variety of technologies that collect and provide information about how our Site is accessed and used by you as well as demographic information about the users of our Site which we may obtain from third parties such as Google or social media that you use (“Usage Information”).  Usage Information may consist of the pages you viewed, the time you viewed them, which beverage information or other content you accessed or provide, in what language, demographic information about you (such as your age, gender and interest areas, where available) and what pages you looked at before viewing the current page so that we get a better idea of how our users interact with our brands and can then tailor and improve accordingly. Most Usage Information that we collect generally can't be linked to you individually, but if we can link it to you then we treat it as Your Information in accordance with this Privacy Policy.
 

2. How and why do we use tracking technologies?

Pernod Ricard uses tracking technologies such as cookies, IP Address or Log files, to gather certain information such as browser type and operating system, referring page, path through site, domain of ISP etc. for the purpose of improving the use and functionality of our websites and to better understand how visitors use our Site and the tools and services offered on it. Tracking technologies help us tailor our Site to your personal needs.
 

  • We use Cookies to improve the use and functionality of our Site and to better understand how visitors use our Site and the tools and services offered on it.  Subject to your consent where required by applicable law, our Site use cookies and similar technologies (“cookies”). Cookies are small files that are placed on your device that serve a number of purposes like letting you navigate between pages efficiently, remembering your preferences, and generally improving your experience. The use of cookies on our Site allows you to enjoy more seamless visits and more accurately measures your behavior on our Site. You can learn more about the cookies we use and how you can disable cookies in the Cookies Policy 

    An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet. We may keep track of Internet Protocol (IP) addresses to (among other things): (i) troubleshoot technical concerns, (ii) maintain website safety and security, (iii) restrict access to our Site to certain users, and, (iv) better understand how our Site are utilized;

    We (or a third party on our behalf) may collect information in the form of logs files that record our Site activity and gather statistics about users' browsing habits. These entries are generated anonymously, and help us gather (among other things) (i) a user’s browser type and operating system, (ii) information about a user’s session (such as the URL they came from, the date and time they visited our Site, and which pages they've viewed on our Site and for how long), and, (iii) other similar navigational or click-stream data. We also use information captured in log file for our internal marketing and demographic studies, so we can constantly improve and customize the online services we provide you. Log files are used internally only, and are not associated with any particular user.

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

Generally, all information collected is used for the purpose provided for which you submitted the information to us or as otherwise identified at the point of collection or in this Privacy Policy. These purposes are mainly the following:


  • When registering or sign-up in our Site: the personal information you provide is used to offer you the benefits and privileges that typically come along with registration e.g. the ability to receive the communications you select at the time of registration or that automatically come with your registration (e.g. subscription to a newsletter, participation in a sweepstake or contest, invitation to or attendance an event organized by Pernod Ricard);

    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.

In addition to the purpose for which you submitted your personal information, you may also be given the option (through a check box or otherwise) to have your information used for an activity or service different from the primary activity or service that you are requesting. For example, if you are signing up for a contest or other promotion, you may also be invited to sign up for newsletters or alerts from our Site hosting the promotion or from other websites or Pernod Ricard products. If you choose to receive these additional services, we will use your information to provide them to you.

To ensure that your personal information remains accurate and up to date and avoid duplication in our database, we will ensure upon each of your interaction with one of our affiliates whether your personal information is still accurate or need to be completed or updated with the additional information you might have provided.

We may also use your email address to send you transactional or administrative communications (e.g., confirmation email when you sign up for, or unsubscribe from, a specific registration or activity), as well as certain service-related announcements (e.g., notices about updates to our Privacy Notice, discontinued features or programs on our Site, changes to our online services or technical support policies, or other related changes), or promotional communications (subject to your consent, where required by applicable law). Collectively, these types of 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, so we can constantly improve, personalize, and customize the products and services we provide you and to better meet your needs.

Subject to applicable law requirement, this may include occasionally combining, updating, or otherwise enhancing the personal information collected through our Site with data we receive 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, etc.) not linked to any personal information about you with personal information collected in other cases (such as during account registration).

4. What happens if you do not wish to provide your personal information?

If you choose not to submit any personal information when requested, you may not be able to participate in certain activities and personalized features on our Site and it will 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 on our Site. However, to simply browse our Site and learn more about Havana Club, you do not need to give us any personal information.

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

Pernod Ricard will never share your personal information with any third party that intends to use it for direct marketing purposes unless we have specifically informed you and you have given us specific permission to do this. Pernod Ricard may share for the purposes mentioned in Article 3 your personal information with its subsidiary companies, that is to say companies in which Pernod Ricard has control through either direct or indirect ownership (collectively “Pernod Ricard Group”) notably, in the following circumstance: the information we collect as described in this Privacy Policy may come from the entity to which you provide it but may also be made available, subject to your consent, through such entity to other entities of the Pernod Ricard Group to provide you with news and promotional information about their products or programs you have shown interest in. If you wish to object to such use of your information, please address your request as indicated in Article 9 of this Privacy Policy, with your name, client reference and your objection that we share your Information with all or part of the entities of the Pernod Ricard Group, and to receive marketing information from them. Pernod Ricard may share for the purposes mentioned in Article 3 your personal information with Pernod Ricard SA (French company located at 12 place des Etats-Unis 75116 Paris, France) subsidiary companies, that is to say companies in which Pernod Ricard SA has control through either direct or indirect ownership (collectively “Pernod Ricard Group”) notably, in the following circumstance: the information we collect as described in this Privacy Policy may come from the entity to which you provide it but may also be made available, subject to your consent, through such entity to other entities of the Pernod Ricard Group to provide you with news and promotional information about their products or programs you have shown interest in. If you wish to object to such use of your information, please address your request as indicated in Article 9 of this Privacy Policy, with your name, client reference and your objection that we share your Information with all or part of the entities of the Pernod Ricard Group, and to receive marketing information from them. Pernod Ricard may also share your personal information with third parties, but only in the following circumstances:
• We may use service providers, agents or contractors to provide support for the internal operations of our Site and to assist us with administering them or the various functions, programs and promotions available on it. Any such third party must at all times provide the same levels of security for your personal information as Pernod Ricard and, where required, are bound by a legal agreement to keep your personal information private, secure and to process it only on the specific instructions of Pernod Ricard;
• We may also disclose your personal information if we are required to do so by law, or if in our good faith judgment, such action is reasonably necessary to comply with legal processes, to respond to any claims, or to protect the safety or rights of Pernod Ricard, its customers, or the public;
• In the event of a merger or acquisition of all or part of Pernod Ricard SA by another company, or in the event that Pernod Ricard SA were to sell or dispose of all or a part of the Pernod Ricard business, the acquirer would have access to the information maintained by Pernod Ricard business, which could include personal information, subject to applicable law. Similarly, personal information may be transferred as part of a corporate reorganization, 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. 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.

6. Are your personal information sent to recipients located in other countries and why?

Pernod Ricard is a global company and your personal information may be transferred across international borders. It may be transferred to countries that have different levels of 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. Pernod Ricard takes the appropriate measures to maintain security of the personal information both during transit and at the receiving location by implementing contractual clauses in accordance with applicable law requirements.
Our main service providers for the operation of our Site are based in the European Union and the United States. The transfer to these services providers either rely on contractual clauses as required by applicable laws. They are also bound by a contract that ensures a high standard of privacy protection and requires (amongst other provisions) that they act only on Pernod Ricard instructions and implements all technical measures necessary on an ongoing basis to keep your personal information secure.

7. How long do we keep your personal information ?

We may store the personal information that you send to us via our Site in our databases. We retain your personal information for as long as your account is active, as we have a contract with you or as needed to provide you the services requested or to answer queries or resolve problems, provide improved and new services. We may also need that your personal information be retained for a reasonable period of time and as necessary to comply with our legal and regulatory obligations, resolve disputes, enforce our agreements, and similar records management purposes.
We may thus retain your personal information for a reasonable period after you stop using Pernod Ricard services or our Site. After this period, your personal information will be deleted from all systems in the Pernod Ricard Group.
If you request that we no longer use your personal information to provide you services e.g., opt-out of receiving email, please contact us as indicated in Article 9. We remind you that you have also a right to have your personal information deleted at any time in accordance with the same Article 9.

8. How do we keep your personal information secure?

Pernod Ricard takes all necessary technical and organizational measures to protect the confidentiality and security of your personal information collected from this Site, including sensitive personal information. These efforts include, but are not necessarily limited to storing your personal information in secure operating environments that are not available to the public and that are only accessible to authorized Pernod Ricard Group employees, and our agents and contractors.

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

You can access your personal information as processed by us by contacting Pernod Ricard Privacy Office at HC_contact@havana-club.com.

You can also contact the Privacy Office to express the following choices:
 

  • - You can request to correct your personal information if it is inaccurate, incomplete or out of date or request the deletion of your Personal information.
    - You also always have the option not to share any of your personal information with us or to 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.
    - If you do not want to receive newsletters, announcements, or other communications and/or services from our Site, please do not opt-in for those communications or services at the time of registration. If you have opted-in and, at a later time, wish to opt-out, please click on the unsubscribe link inserted in our communications.
    - Along with every e-mail communication sent to you, we provide you the opportunity to discontinue receiving future communications (i.e., unsubscribe). Simply follow the unsubscribe process or directions provided in the email.

10. How we treat children's information?

Our Site is 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 Site. By creating an account or engaging in activities or transactions on our Site, you affirm that you are at least eighteen years old and are fully able to enter into and comply with our Terms of Use and this Privacy Policy and be legally bound thereby. If we are notified or learn that a Minor has submitted personal data to us through our Site, we will delete such personal information.

11. Do we link to other third party websites?

Our Site 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 their privacy policies posted on those sites. 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 the external websites you visit before providing your personal information.

12. How can you contact us?

If you have any questions, complaints, or comments regarding this Privacy Policy or our information collection practices, please contact us by writing to Pernod Ricard SA, or sending an email to: HC_contact@havana-club.com .
 
 
Last Update: November 28, 2016