ONLINE PRIVACY POLICY OF PERNOD RICARD ITALIA
Pernod Ricard Italia, in its capacity as the Data Controller, respects your right to privacy when you use our digital communication means (e.g., our websites, mobile applications, social network pages, any online forms to register for our events) and when you communicate with us electronically.
The purpose of this Privacy Policy is to inform you about how Pernod Ricard Italia S.p.A., an Italian legal company with registered office in Milan – Via de Castillia, 23 – 20124 VAT/Tax Code n° 00867250151, registered in the Milan Business Register R.E.A. no. 6952, and the affiliates of the Pernod Ricard group (hereinafter “Pernod Ricard Italia,” “we,” or “our”) collect, store, use, and process Personal Data provided by you through any digital medium managed by Pernod Ricard Italia (hereinafter, “Digital Media”).
INDEX
- What Personal Data do we collect and how?
- How and why do we use tracking techniques?
- For what purposes do we use your personal data, and on what legal basis?
- What happens if you do not want to provide your Personal Data?
- To whom do we disclose your Personal Data and why?
- Are your Personal Data transferred to recipients in other countries, and why?
- How long do we retain your Personal Data?
- How do we protect your Personal Data?
- What are your rights concerning your Personal Data?
- How do we process the Personal Data of minors?
- How can you contact us or the relevant Supervisory Authority?
- Changes to our Privacy Policy.
1. What Personal Data do we collect and how?
Personal Data is collected only for the purposes outlined in the subsequent Section 3 and each time you engage with any of the functions or services offered by our Digital Media.
The type and amount of information collected for the above functions and services may be updated and vary according to Pernod Ricard Italia’s activities.
In compliance with applicable legal requirements, we may use a variety of technologies that collect and provide information about how our Digital Media are accessed and used by the user. We may also use user demographic information from our Digital Media, which we may obtain from third parties such as Google or the social media platforms we use (“Usage Information”). Usage Information may include the pages you’ve viewed, the times you’ve viewed them, information about the beverages or other content you’ve accessed or provided, the language in which you access them, demographic information about you (such as age, gender, and areas of interest, if available), and which pages you’ve looked at before viewing the current page, etc.
2. How and why do we use tracking techniques?
Pernod Ricard Italia employs tracking techniques such as cookies, IP addresses, or log files. Tracking technologies help us personalize our Digital Media according to your individual needs.
- We use cookies to gain a better understanding of how visitors use our Digital Media and the tools and services provided, improving their use and functionality. With the user’s prior consent where required by applicable law, our digital media use cookies and similar technologies (“cookies”). Cookies are small files placed on your device that serve various purposes, such as enabling efficient page navigation, remembering your preferences, and enhancing your overall experience. The use of cookies on our Digital Media enables easier visits and more accurate measurement of your behavior on our site. You can learn more about the cookies we use and how to disable them in Pernod Ricard Italia’s Cookie Policy.
- An IP address is a number used by computers on the network to identify the computer every time it accesses the internet. We may track IP addresses (among other things) to: (i) resolve technical issues, (ii) preserve the protection and security of the website, (iii) limit access to our Digital Media to comply with applicable laws or contractual restrictions, (iv) better understand how our Digital Media are 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 compile statistics on user browsing habits. These records are generated anonymously and help us collect (among other things) (i) the user’s browser type and operating system, (ii) information about a user’s session (such as the URL from which they come, the date and time they visited our Digital Media, and which pages they viewed on our Digital Media and for how long), and (iii) other similar browsing data or click-stream. We also use the information acquired in the log file for our internal marketing and demographic studies, so we can continuously improve and customize the online services we provide. Log files are used only internally and are not associated with any specific user.
3. For what purposes do we use your personal data, and on what legal basis?
We collect information about you to:
- Respond to your service request or fulfill a contract
- When you register or subscribe to our Digital Media (mobile applications, websites, social media, etc.), your Personal Data is used to provide you with the functions and services you subscribe to and to offer you the benefits and privileges typically associated with your registration (for example, receiving the communications you select during registration, being invited to events, participating in contests, etc.).
- When you purchase products on our websites, we use your Personal Data to manage your order and deliver your products.
- Send you commercial or administrative communications (e.g., confirmation emails when you subscribe or unsubscribe from a specific registration or activity), as well as certain service notices (e.g., updates to our privacy information, suspended features or programs on our Digital Media, changes to our online services or technical support policy, or other related changes).
- Allow us to send you marketing information, when you have given your consent:
- In addition to the purpose for which you submitted your Personal Data, you may also be given the option (via a check box or otherwise) to use your Personal Data for an activity or service different from the main activity or service you are requesting. For example, if you register for a contest or other promotions, you may also be invited to subscribe to newsletters or notifications from our Digital Media hosting the promotion or other websites. If you choose to receive these additional services, we will use your Personal Data to provide them.
- When you use the “Send to a Friend” feature, your Personal Data is used only once to send the communication and is not further retained by us, in compliance with local legislation.
- When you use a QR code or equivalent feature displayed on Pernod Ricard Italia products, we use your Personal Data to send you more information about the products on which the QR code or equivalent feature is displayed or other products.
We may also engage in profiling based on monitoring your browsing activities on our Digital Media to better understand your preferences and areas of interest and to tailor our marketing communications to your profile, unless you object as provided in Article 9 of this Privacy Policy.
Pernod Ricard Italia may process Personal Data that involves automated decision-making for the performance of a contract (e.g., to prevent fraudulent payments) or Personal Data subject to your explicit consent, to better serve your needs in line with your preferences.
Please note that the automated tools we use are regularly monitored to ensure that Personal Data is processed fairly. Specific measures, such as data minimization, are implemented when creating profiles. You are encouraged to voice your opinion through the right of access described above. You can also object to the result of automated decision-making by sending an email to the address indicated in Section 11 below.
4. What happens if you do not want to provide your Personal Data?
If you choose not to submit any personal data when requested, it may not be possible to participate in certain activities and personalized functions, or access Digital Media services, and special offers may be unavailable to you. For example, if you refuse to share your email address, you will not be able to receive our newsletters or register in any other way on our Digital Media. However, to simply browse our Digital Media and learn more about our products, you do not need to provide us with any personal data. In any case, we will always inform you of the personal data that are necessary to benefit from a service.
5. Who do we share your Personal Data with and why?
- Within the Pernod Ricard Group
Pernod Ricard may share your Personal Data within the Pernod Ricard Group for the purposes described in section 3, including its affiliates worldwide.
- With third parties
Pernod Ricard Italia may also share your Personal Data with third parties but only in the following circumstances:
- For marketing purposes if you have provided us with your consent.
- For support purposes: We may use service providers, agents, or contractors to provide support for internal operations related to our Digital Media and to assist us in managing or operating the various functions, programs, and promotions available on them. Any third party will consistently provide the same levels of data security as Pernod Ricard Italia and, where required, will be bound by a legal agreement to keep your personal data private and protected and to process them only based on specific instructions from Pernod Ricard Italia.
- For joint and co-sponsored projects and promotional purposes: When we manage a joint or co-sponsored project or promotion on our Digital Media with another company, organization, or other aggregated data, and as part of this event, we 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 collected by (or shared with) a company other than Pernod Ricard Italia as part of such promotion, we will inform you when your Personal Data is collected.
- In cases of disputes and security purposes: We may also disclose your Personal Data if required to do so by law, or if, in our good faith judgment, such action appears reasonably necessary to comply with legal procedures, respond to any claims, or protect the safety or rights of Pernod Ricard Italia, its customers, or the public.
- In the event of a total or partial merger or acquisition of Pernod Ricard Italia by another company, or if Pernod Ricard Italia sells or transfers its business in whole or in part, the acquirer will have access to the stored information related to Pernod Ricard Italia’s business, which may include Personal Data subject to applicable law. Similarly, Personal Data may be transferred as part of a corporate reorganization, insolvency proceeding, or in a similar event, if permitted by and carried out in accordance with applicable law.
6. Your Personal Data is sent to recipients located in other countries and why?
Pernod Ricard Italia is part of a multinational group, and your Personal Data may be transferred across international borders. They may be transferred to countries with a different scope of data protection laws than those existing in the country from which you sent your Personal Data. Your Personal Data may also be transferred within various companies of the Pernod Ricard Group located in different countries. Pernod Ricard Italia adopts appropriate measures to maintain the security of Personal Data both during transit and at the destination through the application of contractual clauses as established by the European Commission, in accordance with applicable rules.
Our main service providers for the operation of our Digital Media are based in the United States. The transfer of Personal Data to these service providers is implemented in accordance with the applicable laws and is based on standard contractual clauses established by the European Commission or the “Privacy Shield.” These service providers are also bound by a contract that ensures a high standard of privacy protection and requires (among other provisions) that they act only on the basis of instructions given by Pernod Ricard Italia and continuously implement the technical measures necessary to keep your Personal Data safe.
7. How long do we retain your Personal Data?
We will retain the Personal Data you have submitted to us through our Digital Media in our databases for as long as your account is active, for the duration of the contract in place with you, or as necessary to provide the requested services or to address inquiries or resolve issues, or to provide better and new services. We may also retain your Personal Data in accordance with our internal retention policy if necessary to comply with our legal obligations, settle disputes, and enforce our agreements.
We may, therefore, retain your Personal Data after you have ceased using the services of Pernod Ricard Italia or our Digital Media, in accordance with legal constraints.
8. How do we protect your Personal Data?
Pernod Ricard Italia 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. This commitment includes, but is not necessarily limited to: (i) storing Personal Data in secure operational environments not available to the public and accessible only to authorized Pernod Ricard Italia employees and our agents and contractors; and (ii) verifying the identity of registered users before they can access their relevant Personal Data that we store.
9. What are your rights regarding your Personal Data?
- If your Personal Data has been processed based on your consent, you can withdraw your consent at any time.
- You can request access to your Personal Data.
- You can request the correction of your personal data if they are inaccurate, incomplete, or not up to date.
- You can request the deletion of your Personal Data (i) if your Personal Data are no longer necessary for the purpose for which they were processed, (ii) if you have revoked the consent to the processing of Data that was based solely on such consent, (iii) if you have contested the processing of your Data, (iv) if the processing of Personal Data is unlawful, (v) if the Personal Data must be deleted to comply with an applicable legal obligation of Pernod Ricard Italia. Pernod Ricard Italia will take adequate measures to inform other entities of the Pernod Ricard Group about such deletion.
- You can request the restriction of processing (i) if the accuracy of the Personal Data is contested to allow Pernod Ricard Italia to verify such accuracy, (ii) if you want to restrict access to the Personal Data rather than delete them despite the fact that the processing is unlawful, (iii) if you want Pernod Ricard Italia to retain your Personal Data because you need them to defend yourself in the context of claims in court, (iv) if you have contested the processing but Pernod Ricard Italia performs a check to verify if it has legitimate grounds for processing that could override your rights, (v) if the processing of Data is based on a legitimate interest of Pernod Ricard Italia.
- You can request the portability of the Personal Data you have provided, especially if the Personal Data have been processed based on your consent or in the execution of a contract.
- You can always choose not to share any of your Personal Data with us. If you choose this option, you may be limited in the activities and functionalities we can provide.
- You have the right to object to the processing of your Personal Data by us, including in cases of data processing for marketing purposes based on profiling.
- In accordance with local regulations, you also have the right to give general or specific instructions on how your Personal Data, processed based on this Privacy Policy, can be used after your death.
10. How do we treat the Personal Data of minors?
Our website is not intended for individuals under the legal drinking age (“Minors”), 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 informed or become aware that a Minor has sent us Personal Data through our Digital Media, we will delete such Personal Data.
11. How can you contact us or the relevant supervisory authority?
In case of questions, complaints, or comments regarding this privacy notice or our information collection practices, please contact us by writing to:
Pernod Ricard Italia S.p.A. Via de Castillia, 23 20124 Milan Italy
or by sending an email to: ITA-Privacy@pernod-ricard.com
For your information, the Data Protection Officer of Pernod Ricard Italia S.p.A. can also be reached at the following email address: groupdpo@pernod-ricard.com
We also inform you that you can file a complaint with the supervisory authority of the country where you are located if you have concerns about the processing of your Personal Data by Pernod Ricard Italia.
12. Changes to our privacy policy
We periodically review our Privacy Policy and will publish any updates on this webpage.
The last update of this Privacy Policy was made in October 2019.