Pernod Ricard is the Data Controller of any personal information you submit to the Site.
1. What personal information do we gather about you and how ?
• Registration or sign-up to our Site: e.g. subscribing to a newsletter that is specific to a Site where applicable;
• Sweepstakes and contests;
• Organization of events (invitation form or online forms on tablets filled out by our hostesses);
• Feedback, questions, or comments through our “Contact Us” form; or
• 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.
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 the Site, domain of ISP etc. for the purpose of improving the use and functionality of our Site 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.
• 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 is utilized;
• We (or a third party on our behalf) may collect information in the form of log 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 files 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?
• When registering or signing-up to 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 at an event organized by Pernod Ricard); and
• 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 check upon each of your interactions with one of our affiliates whether your personal information is still accurate or needs to be completed or updated with the additional information you might have provided.
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 better meet your needs.
Subject to applicable law requirements, 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 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 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, 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;
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 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; and
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 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 relies 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 will 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 your personal information to 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 for similar records management purposes.
We may therefore 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 wish to request that we no longer use your personal information to provide you services e.g., opt-out of receiving emails, 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 the correction of 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.
- In 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?
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 as 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?
Last Update: May 16, 2017