PRIVACY POLICY

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 Pernod Ricard Nigeria Limited and its 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
13. What are the Consent Requirement?
14. What are the Governing Principles?
15. What is the Governing Law?



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:

  • 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
  • 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.

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:

  • Registration or sign-up online: e.g. mobile app, websites, social media or subscribing to a newsletter specific to our Digital Services or creating an account to be a member of a club;
  • ‘Send to a friend’ marketing communications;
  • Sweepstake and contest;
  • Buying products or services online;
  • When doing e-commerce on certain of our websites;
  • Using a QR Code displayed on products;
  • Events (invitation forms or online forms on tablets filled out by our representatives with your input);
  • Tastings;
  • Brand Home;
  • Feedback, questions, enquiries, surveys or comments through ‘Contact us’;
  • Any other request that requires the submission of Personal Data.

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:

  • directly from a third party, e.g.: “Send to a friend” marketing communications or a third party sign-up form from one of our partners;
  • from a third party with your consent, e.g. your bank
  • from cookies on our website (see below, How and why do we use tracking technologies?)
  • via door entry systems and reception logs;
  • from automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems; or
  • from one of our Pernod Ricard Group affiliates.

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:

  • Subject to your consent where required by applicable law, our Digital Services 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 Services allows you to enjoy more seamless visits and more accurately measures your behavior on our Site. 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 IP addresses to (among other things): (i) troubleshoot technical concerns, (ii) maintain website safety and security, (iii) restrict access to our Digital Services to comply with applicable law or contractual restrictions, and, (iv) better understand how our Digital Services 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 Services 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 Services, and which pages they've viewed on our Digital Services 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 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.:

  • To comply with any legal and regulatory obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Respond to your request of service or for the performance of a contract:

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.); Also, where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.

  • When you purchase products on our websites: we use your Personal Data to manage your order and deliver your products.
  • 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 Services, changes to our online services or technical support policies, or other related changes).
  • Allow us to send you marketing information when you consent:

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;

  • Because it is also Pernod Ricard legitimate interest to better serve you:

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 offers 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 and consent to do this.

  • Within the Pernod Ricard Group

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.

  • With third parties

Pernod Ricard 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 support purposes: We may use service providers, agents or contractors to provide support for the internal operations of our Digital Services 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 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: When we run a joint or co-sponsored program or promotion on our Digital Services 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 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 to law enforcement, government officials or other third parties in the event of a subpoena court order or similar legal procedure, or if in our good faith judgment, such action is reasonably necessary to comply with legal processes, to respond to any claims, to report suspected illegal activity or to protect the safety 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 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?

We and our affiliates in the Pernod Ricard Group are a global group and your Personal Data may be transferred across international borders subject to your consent when required. 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 National Information Technology Development Agency (“NITDA”) or other relevant local regulator, 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 NITDA or other relevant local regulator. 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 applicable law and our internal retention procedure as necessary to comply with our legal, tax, accounting, reporting 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. Pernod Ricard Nigeria Limited is required to comply with the Nigeria Data Protection Regulation 2019 (“NDPR”) and other relevant regulations regarding reporting requirements in relation to data breaches and report any personal data breach. Pernod Ricard Nigeria Limited has a duty to report to the NITDA within 72 hours of becoming aware of a breach and to notify you within 7 working days except otherwise directed by the NITDA.
All evidence relating to a personal data breach should be preserved to enable Pernod Ricard Nigeria Limited to maintain a record of such breaches, as required by the data protection laws and to preclude future recurrence.
Pernod Ricard Nigeria Limited will not be responsible for any personal data breach which occurs as a result of:
a) an event which is beyond its control;
b) an act or threats of terrorism;
c) an act of God (such as, but not limited to pandemics, epidemics, fires, explosions, earthquakes, drought, tidal waves and floods);
d) war, hostilities (whether war be declared or not), invasion, act of foreign enemies, mobilisation, requisition, or embargo;
e) rebellion, revolution, insurrection, or military or usurped power, or civil war which compromises the data protection measures on the Digital Services;
f) the transfer of your Personal Data to a third party on your instructions; and
g) the use of your Personal Data by a third party designated by you.


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. Pernod Ricard 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 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 defense 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 (v) if the data processing is based on the legitimate interest of Pernod Ricard.
  • 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 (except if we can demonstrate compelling legal grounds for the processing).

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 our Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Policy 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

Without prejudice to your right to make a complaint at any time to the NITDA, the supervisory authority for data protection issues (www.nitda.gov.ng) for any alleged breach of your data privacy rights, we would appreciate that you contact us in the first instance through the DPO if you have any concerns regarding the protection of your data or this Policy.


12. Changes to our Privacy Policy

We keep our Privacy Policy under regular review and we will place any updates on this web page and we shall notify you of any changes thereon via a notice on our web page. It is also important that the personal data we hold about you is accurate and current. In view of this, we encourage you to always update your Personal Data and keep us informed if there are changes to your Personal Data during your relationship with us.

This Privacy Policy was last updated in 8th March 2021.

13. What are the Consent Requirement?

Generally, we rely on your clear, unequivocal and comprehensible consent as the legal basis for processing your Personal Data. This covers cases where you require us to process your data for the purpose of performing a contract with you, or accessing our services, raising a complaint for clearance of faults; whistleblowing; accessing any of our customer care services; or for use in our marketing, promotional and advertising services. In any of the foregoing instances, we will seek your consent before we share your Personal Data with any third party for such purposes.

With regards to what constitutes data subject’s consent, in accordance with the applicable laws and regulations, Pernod Ricard shall ensure that consent is freely given and is obtained following full disclosure of its intended use and without fraud, coercion or undue influence. Since the performance of a contract with you and provision of our services to you are conditional on your consent, we shall deem that you have granted us the free and express consent to collect and process your Personal Data when you fill any of our forms, access or create an account on our Digital Services, correspond with us by post, phone, email as well as other related medium/platforms.

PLEASE NOTE THAT YOU HAVE THE RIGHT TO WITHDRAW CONSENT AT ANY TIME TO THE PROCESSING OF YOUR PERSONAL DATA BY CONTACTING OUR DATA PROTECTION OFFICER (at [*]). Please note however that the withdrawal of consent will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Where we need to collect personal data by law, or under the terms of a contract we have with you, or to provide our products and our services and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (including to provide you with our products and services). In such case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

14. What are the Governing Principles?

Pernod Ricard will comply with the principles outlined below for the purpose of collecting, storing and using your personal information.

a) Data shall be collected and processed with a specific, legitimate and lawful purpose which shall be consented to by you before collection and processing;
b) Data may be further processed for archiving, scientific research, historical research and statistical purposes for public interest without the obtaining your consent;
c) Data collection and processing shall be adequate, accurate and with consideration for dignity of human person;
d) Data shall only be stored for the period which is reasonably needed and as required by any written law; and
e) Data shall be secured against all foreseeable hazards and breaches such as theft, cyberattack, viral attack, dissemination, manipulations of any kind, damage by rain, fire or exposure to other natural elements.

15. What is the Governing Law?

This Privacy Policy is made pursuant to the provisions of the NDPR and any other relevant Nigerian laws, regulations, or international conventions applicable to Nigeria.

CONSENT CLAUSE

In accordance with the provisions of the NDPR that consent must be a freely given, specific, informed and unambiguous indication of a Data Subject's agreement to the processing of his/her Personal Data, I hereby confirm that I have read the foregoing policy and with a clear understanding of its implications as regards my privacy rights consent to the processing of my personal data by Pernod Ricard.