We take your right to privacy very seriously when you use our websites, our mobile applications, our pages on social networks, online forms and whenever else you communicate electronically with us (our “Digital Services”). That’s why we’ve developed this Privacy Policy to explain how we collect, store, use and process the Personal Data you share with us through our Digital Services.
Please read this Privacy Policy carefully as it contains important information on who we are and how and why we collect, store, use and share your Personal Data. It also explains your rights in relation to your Personal Data and how to contact us or the relevant supervisory authorities in the event you have a complaint. If you do not agree to this Privacy Policy or our Cookies Policy, please do not use our Digital Services.
“We”, “us” and “our” refer to The Absolut Company AB, Pernod Ricard SA and Pernod Ricard SA’s affiliates (these affiliates are collectively referred to as the “Pernod Ricard Group”).
We are the data controller when processing your Personal Data on the conditions described in this Privacy Policy, which includes any Personal Data you submit to this website or another website that links you to this Privacy Policy, such as a microsite that we use to run a promotion or competition (the “Website”).
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 which legal grounds?
4. What happens if you do not wish to provide your Personal Data?
5. Who do we disclose your Personal Data to 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 keep your Personal Data secure?
9. What are your rights regarding Personal Data?
10. How do we treat children's information?
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 means any information that can be used to personally identify you or contact you online or elsewhere.
We may collect and use the following Personal Data about you:
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.
Personal Data we collect from you
We collect most of this Personal Data directly from you - in person, by telephone or email and/or via our website and apps. This usually occurs when you take part in one of our promotional activities or subscribe to one of our Digital Services, for example:
The type and amount of information we collect for the features listed above will vary and depends on the activity.
Personal Data we collect from other sources
We may also collect information:
Subject to applicable law requirements, we may use a variety of technologies that collect and provide information about how our Digital Services is accessed and used by you. We may also use demographic information about the users of our Digital Services, 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, 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. We collect this information to gain a better idea of how people interact with our brands so we can then tailor and improve them accordingly. Most Usage Information that we collect can't be linked to you individually, but if we can link it to you, then we treat it in accordance with this Privacy Policy.
2. How and why do we use tracking technologies?
We use tracking technologies such as cookies, IP address recording or log files, to gather technical information such as your web browser type and which operating system you use, the webpage you came from, your path through our website and your Internet Service Provider. This is so we can improve the functionality of our websites and better understand how visitors like you use our Digital Services and the tools they offer.
Often, individuals will interact with us in multiple ways and will provide us with personal information in different contexts. We may use your personal information to obtain a profile of your different interactions with us and to understand your preferences.
These tracking technologies help us tailor our Digital Services to your personal needs:
3. For what purpose do we use your Personal Data and based on which legal grounds?
Under data protection law, we can only use your Personal Data if we have a proper reason for doing so, e.g.:
o When you register or sign-up in our Digital Services (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 along with your registration (e.g. receiving the communications you select at the time of registration, being invited to events, participating in a sweepstake, etc.);
o 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 Services 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.
o 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;
o When you use a QR Code or equivalent feature displayed on Pernod Ricard 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;
o Subject to your consent when required, we may occasionally combine, update, or otherwise enhance the Personal Data collected through our Digital Services 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 though 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.
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 Personal Data is used to respond to your inquiry or comment.
o 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.
o We may conduct profiling based on monitoring your browsing activities on our Digital Services to better understand your preferences and center of interests and adapt our marketing communications to your profile, unless you object in the conditions set forth in Section 9 of this Privacy Policy.
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, or the Digital 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 Services. However, to simply browse our Digital Services 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. Who do we disclose your Personal Data to and why?
We will never share your Personal Data with any third party that intends to use it for direct marketing purposes, unless we have specifically told you and you have given us explicit permission to do this.
We may share your Personal Data for the purposes mentioned in Section 2 and Section 3 within the Pernod Ricard Group, including its affiliates worldwide.
Pernod Ricard may also share your Personal Data with third parties, but only in the following circumstances:
6. Is your Personal Data sent to recipients located in other countries and why?
We and our affiliates in the Pernod Ricard Group are a global group 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. Your Personal Data may also be transferred between different companies of the Pernod Ricard Group located in different countries. We will, however, take 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 Services are based in the United States. The transfer 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 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 may store the Personal Data that you send to us via our Digital Services in our databases. We will not retain your Personal Data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of Personal Data.
We will store the Personal Data that you sent us via our Digital Services 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 Services according to the statute of limitations.
8. How do we keep your Personal Data secure?
We take 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 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.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
9. What are your rights regarding your Personal Data?
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.
10. How do we treat children's information?
Our Digital Services are not intended for children under the age of majority (“Minor”), so we do not knowingly collect Personal Data from Minors. You must be at least eighteen years old (or, if the legal drinking age where you live is higher, you must be at least that age) to create an account and engage in activities and transactions on our Digital Services. By creating an account or engaging in activities or transactions, you confirm that you are at least eighteen years old (or, if the legal drinking age where you live is higher, that you are at least of legal drinking age) and are fully able to enter into, comply with and be legally bound by any terms of use made available to you and this Privacy Policy. If we are notified or learn that a Minor has submitted personal data to us through our Digital Services, we will delete their 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:
The Absolut Company AB
Att. TAC Privacy Board
Marieviksgatan 19 B
117 97 Stockholm
Sweden
or by sending an email to: privacy@absolut.com
We hope that we can resolve any query or concern you may raise about our use of your information. You also have the right to complain to the Supervisory Authority in the European Union where you work, normally live or where any alleged infringement of data protection laws occurred.
12. Changes to our Privacy Policy
We keep our Privacy Policy under regular review and we will place any updates on this web page.
This Privacy Policy was last updated in February 2019.