User Generated Content - Privacy Policy

23 Nov. 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 choose to allow us to use your social content (“Social Content”) by replying with the hashtag #YesHavanaClub. 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 authorizing us to use your Social Content, please read carefully this Privacy Policy. If you do not agree to this Privacy Policy, please do not allow us to use your Social Content. We reserve the right to make changes to this Privacy Policy. We will notify you of such changes by posting in this Privacy Policy. You are thus invited to review this Privacy Policy each time you grant permission or authorization to feature your Social Content.

Pernod Ricard is the Data Controller of any personal information you submit when authorizing the use of your Social Content.

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 in connection with any use of your Social Content. This information includes data such as your username, image, voice or any other identifying information.

Personal information is only collected with your informed knowledge as described in this Privacy Policy (when you authorize us to use your Social Content).
 

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

All information collected is used for the purpose of enabling us to use your Social Content.

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

If you choose not to submit any personal information when requested, we won’t be able to use your Social Content.

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

Pernod Ricard will never share your personal information with any third party outside the Pernod Ricard Group (as defined below) 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 2 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 use your Social Content.  If you wish to object to such use of your information, please address your request as indicated in Article 8 of this Privacy Policy, with your name, and your objection to us sharing information with all or some 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 use of your Social Content. Any such third party must at all times provide the same levels of security for your personal information as Pernod Ricard and, where required, is bound by a legal agreement to keep your personal information private, secure and to process it only on the specific instructions of Pernod Ricard;
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  • 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;
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  • In the event of a merger or acquisition of all or part of Pernod Ricard by another company, or in the event that Pernod Ricard 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 proceedings, or other similar event, if permitted by and done in accordance with applicable law; 

5. 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 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.

6. How long do we keep your personal information?

We may store the personal information that we collect in the frame of the use of your Social Content.  in our databases. We will retain your personal information for as long as it is needed to use your Social Account.

7. 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. 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.

8. 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 the correction of your personal information if it is inaccurate, incomplete or out of date or request the deletion of your personal information.
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  • 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, we will not be able to use your Social Content.

9. 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: February 13, 2018