Privacy policy

1. What Personal Data do we gather about you and how do we collect it?

Personal Data is collected only for the purposes set out in Section 3 below and each time you participate in any of the features or services offered by our Digital Media.

The types and amount of information collected for the above-mentioned features and services may be updated and vary depending on the activities of Pernod Ricard.

Most Personal Data that we process are collected directly from you, in particular when you fill out forms on our Digital Media and when you contact us. We also collect, if you consent to it, Personal Data about you when you browse our Digital Media through the placement of trackers (see section 2 below and our Cookie Policy).

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. We may also use demographic information about the users of our Digital Media, which we may obtain from third parties such as Google (“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, 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.

2. How and why do we use tracking technologies?

Pernod Ricard uses tracking technologies such as cookies, IP Addresses or Log files. Tracking technologies help us tailor our Digital Media to your personal needs and to offer you content adapted to your interests.
 

• We use cookies to better understand how visitors use our Digital Media and the tools and services offered, and improve their use and functionality, and provide you with content adapted to your interests. Subject to your consent where required by applicable law, our Digital Media 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 Digital Media allows you to enjoy more seamless visits and more accurately measures your behaviour on our Site. You can learn more about the cookies we use and how you can disable cookies in the Pernod Ricard Cookie 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 Digital Media to comply with applicable law or contractual restrictions, and, (iv) better understand how our Digital Media is used;
• We (or a third party on our behalf) may collect information in the form of log files that record activity on the Digital Media and gather statistics about users' browsing habits. These entries are generated anonymously, and help us gather information such as (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 customise 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 Data and based on what legal grounds?

We collect information about you to:

• Respond to your request for services or to perform our contract (on the basis of our legitimate interest, the performance of pre-contractual or contractual measures with you):
  • When you register or sign-up in for our Digital Media (in particular for our careers platform for job applications), 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 along with your registration (e.g. managing your online account);
  • Process any requests, messages, complaints or claims that you communicate to us about our products and/or services. 
• Comply with our legal obligations, including the verification that all users of our Digital Media are of legal drinking age in their country.
• Send you administrative communications (on the basis of our legitimate interest, or the performance of pre-contractual or contractual measures with you): e.g. confirmation email when you sign up for, or unsubscribe from, a specific registration service such as our careers platform, 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)
• To fulfil our legitimate interest in better serving you:
  When the new processing is compatible with the one for which you gave us your consent, we may occasionally combine, update, or otherwise enhance the Personal Data collected through our Digital Media 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 Data about you with Personal Data collected through our offers (such as during account registration).
  We may use the combined above-mentioned information and/or demographic information for our internal marketing and demographic studies and to constantly improve, personalise, and customise the products and services we provide you to better meet your needs. 
• Manage and track your inquiries and comments, including where relevant regarding compliance, via contact forms or contact email addresses: for the performance of a contract in particular.
  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 to ensure your Personal Data is still accurate or needs to be completed or updated with the additional information you will have provided.

4. What happens if you do not wish to provide your Personal Data?

If you choose not to submit any Personal Data when requested, you may not be able to participate or take advantage of personalised features, and the Digital Media services and special services offered to you may be limited. For example, if you refuse to share your email address, you will not be able to register on our Digital Media. Except where required to ensure that users are of legal drinking age, to simply browse our Digital Media and learn more about Pernod Ricard 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?

Pernod Ricard may share your Personal Data with third parties, but only in the following circumstances:
 

• 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 features, 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 Pernod Ricard 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 Pernod Ricard;
• For joint and co-sponsored programs and promotional purposes, to our partners and service providers: When we run a joint or co-sponsored program or promotion on our Digital Media with another company, organisation, 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 Pernod Ricard as part of such promotion, we will let you know this at the time your Personal Data is collected;
• 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 security 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 that Pernod Ricard business, which could include Personal Data, subject to applicable law. Similarly, Personal Data may be transferred as part of a corporate reorganisation, insolvency proceeding, or other similar event, if permitted by and done in accordance with applicable law.

Please note that when you apply for a position in a company of the Pernod Ricard group of companies, the company to which you apply acts as data controller for the purpose of handling your application and the recruitment process. Pernod Ricard will in any event act as data controller for the purposes of creating and managing your career account with the Pernod Ricard group of companies.

6. Is your Personal Data sent to recipients located outside the European Union and why?

Pernod Ricard is a global company and your Personal Data may be transferred across international borders. It may be transferred to countries that have a different level of data protection laws than the one existing in the country from where you submitted your Personal Data. Pernod Ricard takes the appropriate measures to maintain security of the Personal Data both during transit and at the receiving location by implementing contractual clauses as set out by the European Commission, in accordance with applicable law.

Our main service providers for the operation of our Digital Media and partners are based in the United States. The transfer of personal data to these service providers and partners are implemented in accordance with applicable laws and rely on standard contractual clauses as set out by the European Commission. Such service providers and partners, when they act as processors, 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’s instructions and implements all technical measures necessary on an ongoing basis to keep your Personal Data secure.

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 Pernod Ricard services or our Digital Media according to the statute of limitations.

We do not retain or store the information collected for the purpose of verifying that you are of legal drinking age.

The information collected through audience measurement cookies will only be retained for a maximum period of 25 months.

8. How do we secure your Personal Data?

Pernod Ricard takes all necessary technical and organisational measures to protect the confidentiality and security of your Personal Data collected via our Digital Media, including sensitive Personal Data. 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 authorised Pernod Ricard 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, without prejudice to the validity of the processing prior to the withdrawal.
• You can request access to your Personal Data;
• You can request rectification of 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 Pernod Ricard. 
• You can request the restriction of the processing (i) in the event the accuracy of your Personal Data is contested to allow Pernod Ricard 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 Pernod Ricard 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 Pernod Ricard conducts verification to check whether it has legitimate grounds for such processing which may override your own rights.
• 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, or if the data processing is based on the legitimate interest of Pernod Ricard (unless Pernod Ricard can demonstrate overriding compelling legitimate grounds).
• You also have the right to give general or specific instructions on how your personal data processed under this Privacy Policy may be used after your death.

10. How we treat children's Personal Data?

Our Site 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 any activities 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 lodge a complaint with the relevant Supervisory Authority?

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 
France

or sending an email to: groupdpo@pernod-ricard.com

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 Pernod Ricard.

In France, you can contact the Commission Nationale de l’Informatique et des Libertés (CNIL), whose website is accessible here.

12. Computer Security Incident Response Team

The Pernod Ricard CSIRT is an operational team responsible for preventing and responding to information security incidents affecting the Pernod Ricard group.

Description of Pernod Ricard CSIRT
Signature document

For any security incident involving the Pernod Ricard group as the source or target, you can reach out to the Pernod Ricard CSIRT at the following email address: Csirt@pernod-ricard.com.