WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?

This Privacy Statement explains our practices with regard to "Personal Information." Personal Information is any information that can be used to identify, locate or contact you. We collect the following types of Personal Information:

Contact Information that allows us to communicate with you, such as your name, username, mailing address, telephone numbers, email address or other addresses that allow us to send you messages

Relationship Information that helps us do business with you, such as your age, demographics and interests as well as your brand and marketing preferences.

Transaction Information about how you interact with Pernod Ricard USA, including your purchase history, customer account information and information about how you use the Pernod Ricard USA websites and mobile applications.

In many cases, we collect Personal Information directly from you. We may ask you for Personal Information when you interact with us, such as registering on our websites, liking us on social media, signing up to receive promotions or joining a wine club. We may also obtain additional information from third party data suppliers who enhance our files and help us better understand our customers.

HOW DO WE USE YOUR PERSONAL INFORMATION?

Pernod Ricard USA uses your Personal Information to:

Fulfill your orders for products or services and for related activities, such as age verification, product and service delivery, customer service, account management, support and training and to provide other services related to your account;

Develop our relationship with you, such as by delivering personalized content;

Provide you with marketing communications and offers for products and services from Pernod Ricard and, in some cases, our partners, including for offers targeted based on your interests or location;

Administer surveys and other promotional events; and

Manage our everyday business needs, such as payment processing and financial account management, product development, contract management, website administration, forum management, fulfillment, analytics, security and fraud prevention, corporate governance, reporting and legal compliance.

WHEN IS YOUR PERSONAL INFORMATION DISCLOSED TO OTHERS?

Pernod Ricard USA understands that you do not want us to provide your Personal Information to third parties for their own marketing purposes. We limit our sharing of your Personal Information as follows:

We may share your Personal Information with our affiliates, who may only use your Personal Information in compliance with this Privacy Statement.

We may share your Personal Information with our service providers, who are instructed to only use your Personal Information in accordance with our instructions.

We may share your Personal Information with joint marketing partners, but only if you have given us your consent.

We may also disclose Personal Information where needed to affect the sale or transfer of business assets, in connection with a bankruptcy proceeding, to enforce our rights, protect our property, or protect the rights, property or safety of others, or as needed support external auditing, compliance and corporate governance functions. We will also always disclose Personal Information when required to do so by law, such as in response to a subpoena, including to law enforcement agencies and courts in the countries where we operate.

Please note that we may also use and disclose information about you that is not personally identifiable.

COOKIES AND OTHER DATA COLLECTION TECHNOLOGIES

When you visit our website or use our mobile applications, we collect certain Transaction Information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons.

COOKIES

When you visit our website, we place cookies on your device. Cookies are small text files that websites send to your device or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Cookies allow us to recognize you when you return. They also help us provide a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and opt-out of having cookies and other data collection technologies used by adjusting the settings on your browser. All browsers are different, so visit the "help" section of your browser to learn about cookie preferences and other privacy settings that may be available.

FLASH COOKIES

We may use Flash Cookies (also known as Local Stored Objects) and similar technologies to personalize and enhance your online experience. The Adobe Flash Player is an application that allows rapid development of dynamic content, such as video clips and animation. We use Flash cookies for security purposes and to help remember settings and preferences similar to browser cookies, but these are managed through a different interface than the one provided by your web browser. To manage Flash cookies, please see Adobe's website at http://kb2.adobe.com/cps/526/52697ee8.html or visit www.adobe.com.

PIXEL TAGS AND WEB BEACONS

Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions.

TYPES OF DATA WE COLLECT

We collect many different types of information from cookies and other technologies. For example, we may collect information about the device you use to access our website, your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. Our server logs also record the IP address of the device you use to connect to the Internet. An IP address is a unique identifier that devices use to identify and communicate with each other on the Internet. We may also collect information about the website you were visiting before you came to Pernod Ricard USA and the website you visit after you leave our site.

In many cases, the information we collect using cookies and other tools is only used in an aggregated or non-identifiable way, without any reference to Personal Information. For example, we use information we collect about all website users to optimize our websites and to understand website traffic patterns.

In some cases, we do associate the information we collect using cookies and other technology with your Personal Information. This Privacy Statement governs how we use this information when we associate it with your Personal Information.

THIRD PARTY ADVERTISERS AND INTEREST-BASED ADS

Pernod Ricard USA has relationships with Google and other third party advertising companies to deliver interest-based advertisements, targeted to you based on your demographics, brand preferences, online behavior and similar factors. These companies may also perform tracking and reporting functions for us on this website and other websites. These companies may place cookies on your device when you visit our website or other websites so that they can display targeted advertisements to you. These companies do not collect Personal Information in this process, and we do not give any personal information to them as part of this process. However, this Privacy Statement does not cover the collection methods or use of the information collected by these companies.

For more information about third party advertising, please visit the Digital Advertising Alliance (DAA) at www.aboutads.info/consumers. Pernod Ricard USA complies with the Self-Regulatory Principles for Online Behavioral Advertising as administered by the DAA. To opt out of being targeted by some third party advertising companies, you may visit www.aboutads.info/choices.

While Pernod Ricard USA does provide the ability to opt-out of certain targeting advertising as described in this Privacy Statement, we do not respond to "do not track" (a/k/a DNT) signals or similar mechanisms transmitted by web browsers. To learn more about browser tracking signals and Do Not Track please visit http://www.allaboutdnt.org/.

MOBILE APPS

Pernod Ricard USA offers mobile applications that allow you to interact with us and receive personalized content, interest-based ads and other information via your smartphone. When you download our mobile applications, you may choose to allow us to obtain your precise location from your mobile device. We use this information to customize our response to your requests. We may also offer automatic (or "push") notifications. We will provide push notifications only to those customers who opt-in to receive such notifications from Pernod Ricard USA. You do not have to provide location information to Pernod Ricard USA or enable push notifications to use any of our mobile apps. If you have questions about location and notification privacy, please contact your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

YOUR CHOICES

You can always limit the information you provide to Pernod Ricard USA. You can also limit the communications that Pernod Ricard USA sends to you. To opt-out of emails, simply click the link labeled "unsubscribe" at the bottom of any email we send you.

You can exercise certain choices with respect to interest-based ads as set forth above in the "Third Party Advertisers and Interest-Based Ads" section.

Please note that even if you opt-out of promotional messages, we may still need to contact you with important transactional information about your account. For example, even if you opt-out of emails, we may still send you order confirmations and shipping notices.

If you have any questions about your choices or if you need any assistance with opting-out, please contact us.

ACCESS, CORRECTION AND OTHER RIGHTS

Pernod Ricard USA respects your right to access and correct your Personal Information. If you have an online account, you can log into your account at any time to access and update the information you have provided to us. If you need assistance updating your Personal Information, please contact us.

INFORMATION SECURITY AND RETENTION

Pernod Ricard USA has implemented an information security program that contains administrative, technical and physical controls that are reasonably designed to safeguard your Personal Information. For example, we use industry-standard encryption technology to secure sensitive Personal Information when it is being collected and transmitted over the Internet as well as firewalls, site monitoring and intrusion detection software. However, we cannot guaranty that all security measures will be 100% effective at all times. Therefore, you acknowledge that the risk of unauthorized access to your information still exists. We retain your Personal Information as long as needed for our business purposes, in accordance with applicable legal standards.

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Pernod Ricard USA has affiliates around the world, and your Personal Information may be processed outside of your country. By providing us with your Personal Information, you consent to this transfer. We will always protect the privacy and security of your Personal Information in accordance with this Privacy Statement, regardless of where it is processed or stored.

PERSONAL INFORMATION OF PEOPLE UNDER THE LEGAL AGE

We do not intend to collect Personal Information from any individuals under the legal purchase age, or to market alcoholic beverages to anyone under the legal purchase age. Please do not provide us with your Personal Information if you are not of legal age to purchase alcohol in the jurisdiction in which you reside and (if different) in the jurisdiction in which you are interacting with us. If we receive notice or believe that someone under the legal purchase age has provided us with Personal Information we will use reasonable efforts to remove such Personal Information from our files, or to flag such Personal Information and (to the extent permitted by law) retain it for the sole purpose of ensuring that it is no longer used.

PRIVACY POLICIES OF THIRD PARTIES

This Privacy Statement only addresses the use and disclosure of information by Pernod Ricard USA. Other websites that may be accessible through this website have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.

If you interact with us on social media platforms, such as Facebook or Twitter, those interactions are also governed by the terms and privacy policies of the social medial platform providers.

TELL-A-FRIEND FUNCTIONS

Pernod Ricard USA may offer "tell-a-friend" functionality on our website. If you choose to use this function, we will collect Contact Information for your friend. We will automatically send your friend a one-time email with the information you specified or inviting him or her to visit the site. Pernod Ricard USA uses this information for the sole purpose of sending this one-time email and does not retain the information.

FORUMS AND OTHER PUBLIC AREAS

Our websites may provide forums and other areas where you can communicate with others and publicly post information, such as reviews. Prior to posting in these areas, please read the Terms of Use carefully. You have no privacy rights in public postings. All the information you post can be seen by anyone with Internet access, and any Personal Information you include in your posting may be read, collected, and used by others. For example, if you post your email address, you may receive unsolicited messages. Please use caution when posting any Personal Information in the public areas.

 

HOW TO CONTACT US

Please contact us if you have any questions or comments about our privacy practices or this Privacy Statement.