Pernod Ricard UK Ltd., in its role as Data Controller, respects your right to privacy when you use our digital media (such as our websites, our mobile applications, our pages on the social network, any online forms/forums used to register for or participate in our events (“Digital Media”) and communicate electronically with us.
- What Personal Data do we gather about you and how do we collect it?
- How and why do we use tracking technologies?
- For what purposes do we use your Personal Data and on which legal grounds?
- What happens if you do not wish to provide your Personal Data?
- To whom do we disclose Your Personal Data and why?
- Is your Personal Data sent to recipients located in other countries and why?
- How long do we keep your Personal Data?
- How do we secure your Personal Data?
- What are your rights regarding Personal Data?
- How do we process children’s Personal Data?
- How can you contact us or lodge a complaint to the relevant Supervisory Authority?
1. What Personal Data do we collect about you and how?
We collect and process personal data relating to you in connection with your use of our Digital Media. This personal data may include for example:
We may collect and use the following Personal Data about you:
- your name and contact information, including postal address, email address and telephone numbers.
- information to enable us to check and verify your identity, e.g. your date of birth
- your gender information, if you choose to give this to us
- location data
- your billing information, transaction and payment card information
- information to enable us to undertake credit or other financial checks on you
- your personal or professional interests, household, lifestyle, habits and preferences
- information from accounts you link to us, e.g. Facebook and other social platforms
- information about how you use our website, IT, communication and other systems
- your responses to surveys, competitions and promotions
- your IP address and your mobile/tablet/device ID
- information provided to us for your attendance at events, including which events you attend as well as information about access or dietary requirements.
Most of the Personal Data we process is directly collected from you, in particular whenever you fill out a form on our Digital Media or engage with PRUK for example attending a PRUK branded ticketed event or enter a prize promotion or contact us.
Subject to applicable law requirements, we may use a variety of technologies that collect and provide information about how our Digital Media is accessed and used by you. For example, we may communicate with you using third party messaging applications such as WhatsApp. We may also use demographic information about the users of our Digital Media, 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, the items which you placed in your online shopping basket, which beverage information or other content you accessed or provide, in what language, including 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, etc.
Subject to applicable law requirements, we may also use various tools that allow us to personalise and target the ads we or via a third-party display on social media platforms, apps or other third-party websites. Your identity, contact and social media information (i.e. your profile data, social demographics, behavioral data and interests) are processed in this context.
2. How and Why Do We Use Tracking Technologies?
PRUK uses tracking technologies such as cookies, IP Addresses or Log files. Tracking technologies help us tailor our Digital Media 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 Digital Media to comply with applicable law or contractual restrictions, and, (iv) better understand how our Digital Media is used;Joining a loyalty program or subscribing to a newsletter;
- We (or a third party on our behalf) may collect information in the form of logs files that record activity on the Digital Media 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 Digital Media, and which pages they’ve viewed on our Digital Media 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 in isolation.
3. For what purpose do we use your Personal Data and based on which legal grounds?
We collect information about you to:
- Enable you to use our Digital Media: when you register with or sign-up to our Digital Media, your Personal Data is used to provide you with the relevant features and services you subscribe to, and to offer you the benefits and privileges that typically come accompany your registration (e.g. receiving the communications you select at the time of registration, being invited to events, participating in a sweepstake, etc.for the performance of a contract with you or to take steps at your request before entering into a contract;
- Display targeted ads about Chivas Brother’s products and services on social media, apps or third party websites and measuring ad performance. If you consent to the use of your Personal Data for targeted advertising purposes, we will pass on your identification data (hashed) to the social media whose marketing tools we use (see section 5 below), that is to say your surname, first name, contact details and date of birth. Subject to your consent, social media can also identify you through the cookies placed on our Digital Media. Once your data is shared on social media, it is used to enable such media, at your initiative, to find you among other users, and (i) to show you ads about our products and services when you browse the relevant social media, and (ii) to identify, based on your profile on the relevant social media (where you live, age, gender, language, socio-demographic characteristics, interests and behavior), lookalikes who may also be interested by PRUK International Ltd.’s ads. Social media also provide us with reports on the results of our advertising campaigns (click-through rate, conversion rate, audience profile, etc.) to enable us to improve our future campaigns. In the context of these activities, we act as a joint controller together with each social media. We do not, however, collect or access at any time the Personal Data concerning you held by the social media concerned and relating in particular to your profile or your behavior on such social media. This type of Personal Data processing is based on our legitimate economic interest in offering relevant advertising content on social media, tailored to a specific audience.where you have given consent.
- We or via an affiliate company of PRUK or its third party use programmatic advertising to personalise and provide you with relevant advertising based on the personal data we have collected while you are visiting our Digital Media.
- Enable you to purchase products on our websites: we use your Personal Data to manage your order, assist you with purchasing and deliver your products. We may contact you by email if we can see that you have been unable to complete a transaction with a view to assisting you. We can also implement technical solutions to detect fraudulent payment and secure the payment of your purchases on our websites.
- Respond to your questions and comments: if you contact us via an online contact form, such as our “Contact Us” form or through our “Tell Us” compliance reporting system, your Personal Data is used to respond to your query or comment.
- 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 notices, discontinued features or programs on our Digital Media, changes to our online services or technical support policies, or other related changes)
- Send you promotional and marketing information, subject to any preferences that you express when we collect your contact details or subsequently:
- In addition to the purpose for which you submitted your Personal Data, you may also be given the option (through a check box or otherwise) to have your Personal Data 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 Digital Media hosting the promotion or from other websites. If you choose to receive these additional services, we will use your Personal Data to provide them to you. You can opt out of receiving promotional and marketing materials from us at any time by contacting firstname.lastname@example.org;
- When you use the “Send to a friend” feature: this Personal Data is used only once to send the communication and is not further retained by us, as appropriate according to local law;
- When you use a QR Code or equivalent feature displayed on PRUK products: we use your Personal Data to send you more information on the products where the QR code or equivalent feature is displayed or other products.
- Improve and develop our Digital Media;
- Generate and analyse statistics of regarding usage of our Digital Media; and
- Prevent, investigate and detect fraud
We will ensure that your Personal Data remains accurate and up-to-date and avoid duplication in our database, by verifying each of your interactions with us and/or one of our affiliates to ensure your Personal Data is still accurate or needs to be completed or updated with the additional information you will have provided.
The legal bases on which we process your personal data are:
- That this is necessary for the performance of our contract with you, or to take steps prior to entering into a contract with you;
- That this is necessary for compliance with a legal obligation that applies to us;
- That this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party:
We, and/or the third party will only process your personal data for the purposes of our/their legitimate interests where we are of the view that to do so would not constitute an unwarranted interference with your own interests or fundamental rights and freedoms. The legitimate interests for which we process your personal data include our legitimate interests in:
- conducting our business in a responsible and commercially prudent manner;
- promoting our products and services; and
- pursuing our corporate and social responsibility objectives.
- In certain circumstances, that you have given your consent to the processing.
Profiling and Automated Decision Making
Subject to your consent, we may cross the data we collect with your consent with contact details data that you have previously agreed to share with us (e.g., your email address, provided during one of your previous visits in our Digital Media) in order to (i) identify you and (ii) provide you with content and advertising adapted to your interests.
We may process Personal Data involving automated decision making, including for the performance of a contract (e.g. avoid fraudulent payment) or subject to your explicit consent, to better serve your needs in accordance with your preferences.
Please note that the automated tools used are regularly checked to ensure that the Personal Data is processed fairly. Specific measures such as data minimization are implemented when creating profiles. You are invited to express your point of view through the right of access described above. You can also object the result of the automated decision by sending an email to the contact details in Section 11 below.
4. What happens if you do not wish to share your Personal Data?
If you choose not to submit any Personal Data when requested, you may not be able to participate in certain activities and personalized features, or the Digital Media services and special offered to you may be limited. For example, if you refuse to share your email address, you will not be able to receive our newsletters or otherwise register on our Digital Media. However, to simply browse our Digital Media and learn more about PRUK and our products, you do not need to give us any Personal Data. In any event, we will always inform you of the Personal Data that is necessary in order to benefit from a service.
5. To Whom do we disclose your Personal Data and why?
- Within the Pernod Ricard Group PRUK may share for the purposes mentioned in Section 3 your Personal Data within the Pernod Ricard Group, including its affiliates worldwide.
- With third parties. PRUK may also share your Personal Data with third parties, but only in the following circumstances:
- For marketing purposes if you gave us your consent.
- For the purpose of sending you communications (for example, if we use a third party application to communicate with you);
- For support purposes: We may use service providers, agents or contractors to provide support for the internal operations of our Digital Media and to assist us with administering them or the various functions, programs and promotions available on it. Any such third party shall at all times provide the same levels of security for your Personal Data as PRUK and, where required, are bound by a legal agreement to keep your Personal Data private, secure and to process it only on the specific instructions of PRUK;
- For joint and co-sponsored programs and promotional purposes: When we run a joint or co-sponsored program or promotion on our Digital Media with another company, organization, or other reputable third party; and, as part of this event, collect and process Personal Data, we may share your Personal Data with our partner or sponsor, subject to your consent when required. If your Personal Data is being collected by (or is shared with) a company other than PRUK as part of such promotion, we will let you know this at the time your Personal Data is collected;
- For targeted advertising purposes: we share your Personal Data with social media platforms to display targeted ads on them about our products and services to you and people with a similar profile to you. In this context, the social media and PRUK International Ltd. are acting as joint data controllers. We can provide you, on request, with a copy of the data processing agreements entered into with such social media platform. For more information about how such social media process your Personal Data and on how to exercise your rights with them in connection with any further processing of your Personal Data.
- For litigation and safety purposes: We may also disclose your Personal Data 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 PRUK, its customers, or the public;
- In the event of a merger or acquisition of all or part of PRUK by another company, or in the event that PRUK were to sell or dispose of all or a part of the PRUK business, the acquirer would have access to the information maintained by that PRUK 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.
6. Is your Personal Data sent to recipients located in other countries and why?
PRUK is a global company and your Personal Data may be transferred outside the European Economic Area (EEA), including to a country which has a different level of data protection than the one existing in the country from where you submitted your Personal Data. If and to the extent that your Personal Data is transferred outside the EEA, PRUK will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers. These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission or, in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework. If you would like to receive further details of the measures that we have taken in this regard, please contact us at email@example.com.
7. 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, 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.
We may thus retain your Personal Data after you stop using PRUK services or our Digital Media according to the statute of limitations.
8. How do secure your Personal Data?
PRUK takes all necessary technical and organizational measures to protect the confidentiality and security of your Personal Data collected from this website and/or our applications, including sensitive Personal Data. These efforts include but are not necessarily limited to: (i) storing your Personal Data in secure operating environments that are not available to the public and that are only accessible to authorized PRUK 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.
9. What are your rights regarding your Personal Data?
- If your Personal Data has been processed on the basis of your consent, you can withdraw your consent at any time.
- You can request to access your Personal Data
- You can request to rectify your Personal Data if it is 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 purpose of the data processing, (ii) you have withdrawn your consent on the data processing based exclusively on such consent, (iii) you objected to the data processing, (iv) the Personal Data processing is unlawful, (v) the Personal Data must be erased to comply with a legal obligation applicable to PRUK. PRUK will take reasonable steps to inform the other entities of the PRUK group of such erasure.
- You can request the restriction of the processing (i) in the event the accuracy of your Personal Data is contested to allow PRUK to check such accuracy, (ii) if you wish to restrict your Personal Data rather than deleting it despite the fact that the processing is unlawful, (iii) if you wish PRUK to keep your Personal Data because you need it for your defence in the context of legal claims (iv) if you have objected to the processing but PRUK conducts verification to check whether it has legitimate grounds for such processing which may override your own rights (v) if the data processing is based on the legitimate interest of PRUK.
- You can request the portability of the Personal Data you provided to us, in particular if the Personal Data processing is based on your consent or the performance of a contract.
- You always have the option not to share any of your Personal Data with us. If you choose this option, you may be limited in the activities and features we can provide you.
- You have the right to object to the processing of your Personal Data by us, including for marketing purpose based on profiling.
10. How do we treat children’s Personal Data?
Our Digital Media is not intended for children under the legal drinking age (“Minor”), so we do not knowingly collect personal data from Minors. You must be at least eighteen years old to create an account and engage in activities and transactions on our Digital Media. 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.
11. How can you contact us or the relevant Supervisory Authority?
Data Privacy Champion PRUK, Building 7 Chiswick Park, 566 Chiswick High Road, London W4 5YG
or sending an email to: firstname.lastname@example.org
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 of processing of your Personal Data by PRUK.