DATA PROTECTION AND PRIVACY POLICY

Pernod Ricard Winemakers Spain, 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/forms to register to our events…) “Digital Media” and communicate electronically with us.

The purpose of this Privacy Policy is to inform you how Pernod Ricard Winemakers Spain, S.A.U, a corporation duly organized under the laws of Spain, with its registered address at Paseo Mikeletegi, nº 71, 2ª planta, 20009 – San Sebastián (Spain) and its affiliates (all together “Pernod Ricard”, “we,” or “our”) collect, store, use and process your Personal Data provided through any digital media operated by Pernod Ricard (“Digital Media”).

Topics

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

2. How and why do we use tracking technologies?

3. For what purposes do we use your Personal Data and on what legal grounds?

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

5. To whom do we disclose Your Personal Data and why?

6. Is your Personal Data sent to recipients located in other countries and why?

7. How long do we keep your Personal Data?

8. How do we secure your Personal Data?

9. What are your rights regarding Personal Data?

10. How do we process children’s Personal Data?

11. How can you contact us or lodge a complaint to the relevant Supervisory Authority

12. Changes to our 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 when using the above-mentioned features and services may be updated and vary depending on the activities of Pernod Ricard Winemakers Spain (for example: your name and contact details, including your address, telephone and email address; your age; your IP address; your credit/debit card; any other information relating to you that you provide to us or that we generate about you in connection with your use of our Digital Media).

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 contact us. We also collect, with your consent, Personal Data concerning you whenever you browse on our Digital Media through the use of tracking technologies (in this respect see Section 2 below as well as our Cookie Policy).

Subject to applicable law requirements, we may also use various tools that allow us to target the ads we display on social media. 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?

Pernod Ricard Winemakers Spain uses tracking technologies such as cookies, IP Addresses or Log files. Tracking technologies help us tailor our Digital Media to your personal needs and 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, improve their use and functionality and provide you 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 such as letting you browse between pages efficiently, remembering your preferences, and generally improving your experience. We may collect data such as your actions on our Digital Media; your preferred site category; your IP address and country of leaving; your visit time; the links on which you click. The use of cookies on our Digital Media allows you to enjoy more seamless visits and more accurately measures your behaviour on our Digital Media.You can learn more about the cookies we use and how you can disable cookies in the Cookies 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 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 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 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 Data and based on what legal grounds?

We collect information about you to:

Respond to your request for services or to perform our contract (based on our legitimate interest, to carry our precontractual or contractual measures with you)

- - When you register or sign-up in our Digital Media (mobile app, websites, social media, etc.), 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 with your registration (e.g. management of your online account, being invited to events, participating in a sweepstake, etc.);
  - Manage your order and deliver products purchased on our Digital Media. We can also implement technical solutions to detect fraudulent payments and to secure the payment of your purchases on our websites;
  - Handle any claims or complaints you make about our products and/or services.

Send you transactional or administrative communications (based on our legitimate interest or to carry out precontractual or contractual measures with you): (e.g. confirmation email when you sign up for, or unsubscribe from, a specific service or feature), 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)
Allow us to send you marketing information when you consent:
- We may use your Personal Data, with your consent, to send you (ourselves or via Pernod Ricard UK) announcements and promotional information about our products and services by email or by text messages. 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.
- When you use the third-party sponsorship (“Send to a friend”) feature: the Personal Data collected 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 Pernod Ricard Winemakers Spain 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;
To fulfil our legitimate interest in better serving your needs:
- Whenever this new processing is compatible with the processing for which you have given 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, personalize, and customize the products and services we provide you to better meet your needs. Some of the tools we use may involve automated individual decision -making subject to applicable law.
Manage and track your inquiries and comments, including where relevant regarding compliance, via contract forms or contact email addresses: for the performance of a contract in particular.
- For administrative and management purposes and internal centralization, we may send your Personal Data to Pernod Ricard Group
Display (ourselves or via Pernod Ricard UK) targeted ads about Pernod Ricard products and services on the social media, apps or third party websites you are registered on 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 Pernod Ricard’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.
- We or via an affiliate company 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.

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.

We (or via Pernod Ricard UK) may engage in automated profiling by monitoring your browsing activities on our Digital Media (in particular via the use of cookies) to better understand your preferences and centre of interests and adapt (i) our online content/contextual experience and (ii) our marketing communications (by email and on social media) to your profile, unless you object or withdraw your consent.

In order to do so and subject to your consent regarding the use of cookies, we may cross the data we collect regarding your online behavior 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)

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 provide 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, 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 receive our newsletters or otherwise register on our Digital Media. However, to simply browse our Digital Media and learn more about Pernod Ricard Winemakers Spain 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?

To affiliates within the Pernod Ricard Group
Pernod Ricard Winemakers Spain may share your Personal Data within the Pernod Ricard Group, including its affiliates worldwide for the purposes mentioned in Section 3. In particular, regarding promotional and marketing information and targeted advertising, Pernod Ricard Winemakers is the data controller for the collection of your Personal Data but Pernod Ricard UK is the data controller for the activation/use of such Personal Data.

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

- For marketing purposes, with our service providers, if you gave us your consent.
- 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 Winemakers Spain 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 Winemakers;
- For joint and co-sponsored programs and promotional purposes with our partners and service providers: 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 Pernod Ricard Winemakers Spain 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 Pernod Ricard 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, we invite you to view their privacy policy on their website.
- 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 Pernod Ricard Winemakers Spain, its customers, or the public;
- In the event of a merger or acquisition of all or part of Pernod Ricard Winemakers Spain by another company, or in the event that Pernod Ricard Winemakers Spain were to sell or dispose of all or a part of the Pernod Ricard Winemakers Spain business, the acquirer would have access to the information maintained by that Pernod Ricard Winemakers Spain 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?

Pernod Ricard Winemakers Spain is a global company and your Personal Data may be transferred across international borders, to countries with different level of data protection than the country from where you submitted your Personal Data. Your Personal Data may also be transferred between different companies of the Pernod Ricard Group located in different countries. Pernod Ricard Winemakers Spain 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 are based in the United States, as are our partners. Transfers of personal data to these service providers are implemented in accordance with applicable laws and rely on standard contractual clauses as set out by the European Commission or on the Privacy Shield. Such service providers and partners, when acting as processorts, 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 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, 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.

We may thus retain your Personal Data after you stop using Pernod Ricard Winemakers Spain services or our Digital Media according to the statute of limitations.

Once the account is canceled, we will store your data for a maximum period of 24 months, except in the event you have enjoyed any of our products and or services. In this case, we will keep your Personal Data for a maximum period of 10 years. In any case, if the law, public administrations or courts set a higher period than those indicated in this paragraph for the obligation of store of documentation where your Personal Data can be recorded, we will apply these retention periods.

We may thus retain your Personal Data after you stop using Pernod Ricard’s services or our Digital Media according to the statute of limitations.

8. How do we secure your Personal Data?

Pernod Ricard Winemakers Spain takes 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 authorized 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 impact on lawfulness of processing based on consent before its withdrawal.
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 Pernod Ricard Winemakers Spain. Pernod Ricard Winemakers Spain will take reasonable steps to inform the other entities of the Pernod Ricard 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 Pernod Ricard Winemakers Spain 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 Winemakers Spain to keep your Personal Data because you need it for your defense in the context of legal claims (iv) if you have objected to the processing but Pernod Ricard Winemakers Spain 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 Pernod Ricard Winemakers Spain.
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 and is carried out by automated means (i.e. excluding paper files)
You have the right to object to the processing of your Personal Data by us, at any time, for direct marketing purpose, for marketing purpose based on profiling, for the purposes of targeted advertising on social media or if the data processing is based on the legitimate interest of Pernod Ricard (except if we can demonstrate compelling legitimate grounds for the processing).
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.
According to the local law, you have also the right to give general or specific instructions on how your personal data processed under this Privacy Policy may be used after your death.

According to the local law, you have also the right to give general or specific instructions on how your personal data processed under this Privacy Policy may be used after your death.

You can enforce your Personal Data rights through the following link: https://protecciondedatos.pernodricardwinemakersspain.com/

10. How we treat children’s Personal Data?

Our Digital Media are 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?

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 Winemakers Spain
Paseo Mikeletegi nº 71, 2ª planta
20009 San Sebastián (Gipuzkoa)
Spain

Or by clicking here.

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 Winemakers Spain.