Pernod Ricard S.A. respects your right to privacy when you use our digital media (such as our websites, our mobile applications, our social media pages, and any online registration forms for our events – together the “Digital Media”) and communicate electronically with us.
This privacy policy (the “Privacy Policy”) applies to the following persons (“you”):
- All users of our Digital Media;
- The participants to our surveys.
The purpose of this Privacy Policy is to inform you how Pernod Ricard S.A. collects, stores and uses the personal data collected from you.
This Privacy Policy may be updated at any time as a result of, among others, legal, technical or commercial changes. We will notify you, by appropriate mean, of any substantive change in this Privacy Policy. You are also invited to regularly read this Privacy Policy to make sure you are aware of the latest version.
1. WHO IS THE DATA CONTROLLER FOR THE PROCESSING OF YOUR PERSONAL DATA?
Pernod Ricard S.A., company incorporated under the laws of France under the number 582 041 943, with a share capital of 391 017 252,25 €, having its registered office at 5, Cours Paul Ricard, 75008 Paris, France (“Pernod Ricard S.A.” or “we”, “our”, “us”) acts as the “data controller” for the processing of your personal data (i.e. it is the entity that determines “why” and “how” your personal data are used).
Pernod Ricard S.A. acts as the data controller for processing personal data in connection with the security and operation of the website. This includes contact forms, newsletter inscription and inscription to lotteries through the Site.
Please, note that with respect to the processing of personal data for marketing-related activities, including the collection of consent (“opt‑in”) for receiving marketing communications as indicated at the time of collection, the Pernod Ricard Group entity corresponding to your location of residence acts as the data controller.
For more information on how your data is processed for these purposes, please find the privacy policies applicable to your location of residence here: https://www.pernod-ricard.com/en/pernod-ricard-privacy-policies-by-country.
2. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU AND HOW?
“Personal data” refers to any information that may identify you directly (e.g., your name) or indirectly (e.g., your phone number, postal/email address, pseudonymized data such as a unique identifier).
We collect most of the personal data directly from you, for example by filling out a contact form, creating an account, using interactive features, requesting information, or responding to surveys.
We may also collect personal data from cookies on our Website (for more details see our Cookie Policy available in the footer of each of our Website).
Depending on the purposes of collection, personal data collected are the following:
- – your name, your gender and contact details, including your postal address, email address, and phone numbers, and, where applicable, your business contact details; information allowing us to verify and check your identity, such as your date of birth;
- – location data;
- – information on how you use our Digital Media;
- – your responses to surveys;
- – your IP address and your mobile/tablet/device identifier;
- – contact form information (e.g., customer service inquiries, comments);
- – content you may provide to us (e.g., images, comments, audio recordings, etc.).
The personal data collected is necessary to achieve the purposes described in section 3 below. If you do not provide the personal data we request, it may delay or prevent us from providing you with services.
3. FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS ARE PERSONAL DATA PROCESSED?
We collect and process personal data that are relevant, adequate, not excessive and strictly necessary for the purposes pursued.
You will find below a table listing:
The data retention periods applicable to each processing activity (i.e., how long we keep your personal data before deleting or anonymizing it).
The different purposes of the processing operations (i.e. why we use your personal data);
The legal basis on which we rely to carry out the processing (i.e. why we are authorized to use your personal data);
1. Restrict access to our Digital Media
Purpose of the processing:
Restrict access to our Digital Media in order to comply with applicable legal or contractual restrictions.
Legal basis:
Our compliance with our legal obligations.
Data retention period:
The time of your visit on the website, unless you tick the “remember me” box.
2. Ensure the proper functioning of our Digital Media
Purpose of the processing:
Ensure the proper functioning of our Digital Media, for example through audience measurement and statistics, using trackers such as cookies that are strictly necessary for the provision of an online communication service expressly requested by the user, or solely intended to enable or facilitate communication by electronic means.
For example, this includes trackers used for user interface customization (such as language selection or the presentation of a service), where such customization is an expected element of the service, as well as trackers enabling load balancing of equipment contributing to a communication service.
For more information, please refer to our Cookie Policy available in the footer of each of our Websites.
Legal basis:
Our legitimate interest, namely ensuring the proper functioning of our Digital Media.
Where necessary, your consent.
Data retention period:
The period necessary for the provision of the service, with a maximum duration of 13 months, unless you withdraw your consent earlier.
3. Handle requests or feedback relating to our products and/or services
Purpose of the processing:
Handle any request or feedback you make about our products and/or services, including complaints, comments, satisfaction surveys, and inquiries sent via our contact forms or contact email addresses.
Legal basis:
Depending on the purpose of your request:
If your request is not related to a product or service already purchased from or subscribed to by you: our legitimate interest, more specifically our economic/business interest in serving your needs and allowing you to communicate with us simply and efficiently.
If your request is related to a product or service already purchased from or subscribed to by you: the performance of a contract (e.g. our Terms & Conditions) between us and you.
Data retention period:
If your request is not related to a product or service already purchased from or subscribed to by you: a maximum of 3 years from the closing of the case, plus the statutory retention periods required to comply with our legal obligations.
If your request is related to a product or service already purchased from or subscribed to by you: the time necessary to manage the commercial relationship, plus a maximum of 3 years from the end of the commercial relationship, plus the statutory retention periods required to comply with our legal obligations.
4. Maintain the safety and security of our Digital Media
Purpose of the processing:
Maintain the safety and security of our Digital Media and prevent and combat the fraudulent use of our websites or services.
Legal basis:
Our legitimate interest, more specifically our business and economic interest in providing you with secure Digital Media and services.
Data retention period:
The time of your visit on the website.
5. Send transactional, legal or administrative communications
Purpose of the processing:
Send you transactional, legal or administrative communications.
For example, we may send you a confirmation email when you sign up for or unsubscribe from a specific service or feature, or notices regarding updates to our privacy notices.
Legal basis:
Performance of a contract (e.g. our Terms & Conditions) between us and you, including the performance of pre-contractual measures, in order to provide you with the requested service.
For legal communications: compliance with our legal obligations.
Data retention period:
If you have purchased or subscribed to a product or service from us: the time necessary to manage the commercial relationship, plus up to 3 years from the end of the commercial relationship, together with the statutory retention periods required to comply with our legal obligations.
If an account has been created but no product has been ordered: 3 years after your last login.
6. Establish evidence and defend our rights
Purpose of the processing:
Establish any evidence necessary to defend our rights and manage pre-litigation and litigation proceedings.
We may also process your data to respond to requests from relevant authorities and defend our rights based on our legal obligations.
For example, if we receive a subpoena or another legal request, we may need to inspect the data we hold in order to determine how to respond.
Legal basis:
Our legitimate interest in defending our rights.
Data retention period:
For the duration of any dispute or litigation, plus the time necessary to comply with our legal obligations in this regard.
7. Manage a merger, acquisition or corporate reorganization
Purpose of the processing:
Manage a merger or acquisition of all or part of Pernod Ricard S.A. or a corporate reorganization.
Legal basis:
Our legitimate interest, namely our economic/business interest in anticipating and carrying out a corporate transaction or reorganization.
Data retention period:
Not specified in the source text.
8. Handle data subjects’ rights
Purpose of the processing:
Handle requests relating to the exercise of your data protection rights, such as requests to delete your personal data.
Legal basis:
Our compliance with our legal obligations.
Data retention period:
3 years from the request, plus the duration of any dispute or litigation.
4. TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA AND WHY?
To internal authorized employees
We will communicate your data to our employees who need to process your personal data for the purposes specified in Section 3 of this Privacy Policy, in particular to our sales, accounting and tech teams. Your personal data can also be processed by employees from Pernod Ricard Group’s affiliates worldwide, where Pernod Ricard Group’s affiliates provide support services (IT, administrative) as processor of Pernod Ricard S.A.
- To service providers
- For IT support purposes: we will share your data with our IT support service providers (for hosting, maintenance and technical support services) to help us for the internal operations of our Digital Media and to assist us with administering them or the various features, programs and promotions available on it.
- To other third parties
- For litigation and safety purposes: we may also disclose your personal data to authorities and/or external counsels 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 security or our rights, customers, or the public.
In the event of a merger or acquisition of all or part of Pernod Ricard S.A. by another company, or in the event that we were to sell or dispose of all or a part of our business, the acquirer may have access to the information maintained by our business, which could include personal data, subject to applicable law. Similarly, personal data 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. If applicable, the acquirer who will act as the new data controller will process your personal data in the conditions provided in the acquirer’s privacy policy.
5. Is your Personal Data sent to recipients outside the European Union?
As we are part of Pernod Ricard Group, your personal data may be transferred to countries outside the European Economic Area, where Pernod Ricard Affiliates and third parties operate, such transfers will take place only if permitted and carried out in compliance with applicable laws. For these transfers, we take the appropriate measures to maintain security of the personal data both during transit and at the receiving location and ensure that countries have been deemed to provide an adequate level of protection by the European Commission, or that third parties implement relevant safeguards provided by applicable laws i.e. the Standard Contractual Clauses as set out by the European Commission or, where applicable, Binding Corporate Rules. You may obtain a copy of these safeguards at any time: to do so, please contact us at the email address specified in section 10 of this Privacy Policy.
6. HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will store the personal data that you sent us via our Digital Media in our databases as long as your account is active, for the duration of the contract with you or as needed to provide you the services you requested or to answer queries or resolve problems, or else to provide improved and new services.
We may also retain your personal data in accordance with our internal retention procedure as necessary to comply with our legal and regulatory obligations, resolve disputes and enforce our agreements.
You can find details on the data retention periods implemented in the table in section 3.
7. How do we secure your Personal Data?
We take all necessary technical and organizational measures to protect the confidentiality and security of your personal data collected via our Digital Media. These efforts include but are not necessarily limited to: (i) storing your personal data in secure operating environments to which the public does not have access, but only our authorized employees, and our agents and contractors; and, (ii) verifying the identities of registered users before they can access the personal data we maintain about them.
Our Digital Media may linkup users to other websites of our third parties and/or affiliates or subsidiaries, through hyperlinks; this is a service available to you as a user of the site. Such links do not constitute an endorsement by us of the linked sites, their content, including products, advertising or any other materials featured on them. We have no control over these linked sites and cannot be held responsible or liable for their content, including products, advertising or any other materials featured on them, or any purchase you may choose to make on these linked sites.
8. WHAT ARE YOUR RIGHTS REGARDING YOUR PERSONAL DATA?
You have the following rights with respect to your personal data:
If your personal data has been processed on the basis of your consent, you can withdraw your consent at any time (see the table in section 3 of this Privacy Policy to understand which processing are based on your consent).
You have the right to obtain a copy of the personal data we hold about you.
You can request to rectify your personal data if they are inaccurate, incomplete or out of date.
You can request the erasure of your personal data (i) if your personal data is no longer necessary for the purposes mentioned above in section 3, (ii) if you have withdrawn your consent for a data processing based exclusively on such consent, (iii) if you have objected to the data processing, (iv) if the personal dataprocessing is unlawful, (v) if the personal datamust be erased to comply with a legal obligation applicable to us. Please note however that this is not an absolute right, as we may be obliged to retain your personal data for legal or legitimate reasons.
You can request the restriction of the processing. You may ask us to restrict the processing of your personal data in specific cases (e.g., if you contest the accuracy of your personal data).
You have the right to data portability, meaning to receive (and transmit to another data controller) personal data that you have provided to us and that we hold about you in a structured, commonly used and machine-readable format. This applies only where the processing is based on your consent or the execution of pre-contractual measures / performance of a contract and is carried out by automated means (see the table in section 3 of this Policy to understand which processing rely on these legal basis).
If you are a French citizen, you also have the right to give general and specific instructions to decide the fate of your personal data after your death.
You have the right to object to the processing of your Personal Data by us, at any time, (i) for direct marketing purpose including based on profiling (if applicable), or (ii) if the data processing is based on our legitimate interest, except if we can demonstrate compelling legitimate grounds for the processing – (see the table in section 3 of this Privacy Policy to understand which processing are based on our legitimate interests).
To exercise all these rights, you can send a request to: [email protected].
You are informed that you can also lodge a complaint with the supervisory authority of the country where you are located if you have any concern about the conditions we process your personal data. In France, you can contact the Commission Nationale de l’Informatique et des Libertés (CNIL), 3 Place de Fontenoy, 75007 Paris via their website at: https://www.cnil.fr/fr.
However, we invite you to contact us at the address below before filing any complaint before any supervisory authority.
9. How do we treat children’s Personal Data?
Our Digital Media are not intended for children under the legal drinking age (“Minor”), we have implemented an age gate so we do not knowingly collect personal data from Minors. If we are notified or learn that a Minor has submitted personal data to us through our Digital Media, we will delete such personal data.
10. 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,
5, cours Paul Ricard
75008 Paris Cedex
France
or sending an email to: [email protected]
or by sending an email to Pernod Ricard Global Data Protection Officer that you can reach at [email protected].