This Privacy Statement describes how Pernod Ricard USA, LLC and its brands in the United States, including but not limited to the Pernod Ricard family of brands listed at https://www.pernod-ricard-usa.com/our-brands (together, “Pernod Ricard”, “we”, or “us”), collect, use, share and otherwise process personal information when you use our websites, platforms and mobile applications that link to this Privacy Statement (together, the “Sites”), when you communicate with us electronically, or otherwise provide us with your Personal Information.
Our Sites are intended for visitors based in the United States. If you are a website visitor based in the European Union, please visit https://www.pernod-ricard.com/en/privacy-policy.
If you are a candidate for a position at Pernod Ricard in the United States, please refer to our Privacy Notice for United States Candidates, available at https://www.pernod-ricard.com/en/data-protection-information-notice-candidates under the subheading “United States of America”.
If you are a California staff member, please refer to our Privacy Notice for California Staff Members, available at https://www.pernod-ricard.com/en/locations/usa/privacy-notice-california-staff-members.
| Notice at Collection for California Consumers: If you are located in California, please review our Supplemental Notice for California Residents appended as a supplement to this Policy. |
1. 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, as used in this Privacy Statement, is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual.. We may collect the following types of Personal Information:
• Contact information that allows us to communicate with you, such as name, username, mailing address, telephone number, country of residence, email address or other identifiers.
• Relationship information that helps us do business with you, such as your age, interests and other general background information, as well as your brand and marketing preferences.
• Transaction information, including your purchase history and customer account information.
• Usage data about how you use our Sites as further described in the Cookies and Similar Technologies section of this Notice, as well as your general location when you use our Sites, to give us a better idea of how you interact with our brands and content.
In many cases, we collect Personal Information directly from you. We may ask for your Personal Information when you interact with us, such as registering on our Sites, following us on social media, signing up to receive marketing news and invites, or joining a wine club. We may also obtain additional information from business partners to whom you give permission to share information with us to enhance our files and help us better understand our consumers.
2. How do We use your Personal Information?
We may use your Personal Information to:
• Fulfill your orders for products, services, and related activities, such as to send you communications related to your order, to respond to your inquiries, to perform age verification, product and service delivery, customer service, account management, support and related training of our personnel involved in such activities, 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 us and, in some cases, our partners, including for offers targeted based on your interests or location;
• Administer market research, surveys and promotional events that you may voluntarily choose to join;
• Match it with other public and private data sources in order to enhance our records, such as appending additional information to your profile, or the records of our business partners. We also may work with other providers who also possess information about you in order to reach you through different methods and platforms, such as on a social media platform that you use;
• 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.
• Comply with law, regulation, legal process, and internal policies.
• Exercise and defend legal claims.
• We may also aggregate and/or anonymize Personal Information and analyze that data for statistical, research, or any other purposes permitted by applicable data protection laws.
If we intend to use your Personal Information in a manner materially different than as set out in this Privacy Statement, we will provide you with supplemental information on such other purpose either at the time of collection or prior to such use consistent with applicable privacy law.
3. When is your Personal Information disclosed to others?
We limit our sharing of your Personal Information as follows:
• Affiliates: We may share your Personal Information with, or otherwise make it available to, our affiliates, who may only use your Personal Information in compliance with this Privacy Statement.
• Service Providers: We may share your Personal Information with our service providers, who are instructed to only use your Personal Information in accordance with our instructions.
• Partners: We may share your Personal Information with unaffiliated joint marketing partners, but only if you have given us your consent.
• Business Transfers and Legal Purposes: We may also disclose Personal Information where necessary 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 may also disclose Personal Information when required to do so by law, such as in response to a subpoena, including to law enforcement agencies, courts, or other governmental bodies.
Please note that we may also use and disclose information about you in a form that is not personally identifiable, such as in an aggregate or other form that no longer identifies you, as consistent with applicable data protection laws.
Pernod Ricard does not collect, use, or sell Personal Information for the purpose of training large language models.
4. Cookies and Similar Technologies
When you visit our Sites, we may collect Personal Information by automated means, using technologies such as cookies, pixel tags, browser analysis tools, server logs and web beacons. For example:
Cookies
When you visit our Sites, we may place cookies on your device. 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. They also help us provide you with a customized experience and enable us to detect certain kinds of fraud. In many cases, you can manage cookie preferences and disable the use of cookies through cookies preference tools on our Sites or by adjusting the settings on your browser. All browsers are different, so visit the settings of your browser to learn about cookie preferences and other privacy settings that may be available. Please note that certain features of our Sites may not be available if certain cookies are disabled. You can find more information about cookies and how they work at https://www.allaboutcookies.org.
Pixel Tags and Web Beacons
Pixel tags and web beacons are tiny graphic images that may be placed on our Sites or in our emails that allow us to determine whether you have performed a specific action. When you access these pages or open 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 Through Cookies and Similar Technologies
We may automatically collect personal and other types of information from cookies and similar technologies. For example, we may collect information about the device you use to access our Sites, your operating system type, browser type, referring domain, and other system settings, as well as the language your system uses and the country, state, zip code and time zone where your device is located. Our server logs also record the Internet Protocol (IP) address of your device. We may also collect information about the Sites you visit before and after our Sites. 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 Sites users to optimize Our Sites and to understand Sites traffic patterns. In some cases, consistent with this Privacy Statement, we may associate the information we collect using cookies and other technology with your Personal Information
Third Party Advertisers and Interest-Based Ads
We may allow service providers and third parties to collect information about the users of our Sites. Such third parties may collect Personal Information about your online activity over time and across different Sites, a practice also known as online behavioral advertising. We have relationships with Google and other third-party advertising companies to deliver interest-based advertisements to you based on your brand preferences, general demographics, online behavior and other similar information. These companies may also perform tracking and reporting functions for us on our Sites. These companies may place cookies on your device when you visit our Sites so that they can display targeted advertisements to you.
For more information about interest-based advertising, please visit the Digital Advertising Alliance (DAA) at www.aboutads.info/consumers. We comply 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.
You may also opt out of cookies at any time by refusing cookies through the cookie pop up when you visit any of our Sites or by clicking “Cookies Management” at the footer of our Sites’ homepages.
We may work with third parties that use algorithms to determine if you have interacted with our services on multiple devices and to match such devices together. We may then display interest-based advertisements to you across your devices or otherwise use the combined data for purposes under this Privacy Statement. For example, if you exhibit certain behaviors on your desktop computer, we may serve interest-based advertisements to you on your smartphone based upon those behaviors if we have linked both of those devices to you. If you would like to opt-out of such cross device matching, please visit the Digital Advertising Alliance (DAA) at www.aboutads.info/consumers.
Our Sites’ cookie management tool is configured to honor opt-out preference signals sent by Global Privacy Control (“GPC”) within your browser. Please note that due to technical limitations, the GPC signal may only be recognized within your current browser. For more information on GPC, please visit https://globalprivacycontrol.org.
5. Mobile Applications
We may offer mobile applications that allow you to interact with us and receive personalized content, interest-based ads and other information via your device. We may collect personal information from mobile applications in the same manner as we do through all of our Sites. Through our mobile applications, we may also collect general location information indicating the estimated or approximate physical location of you or your device (e.g. IP address or zip code), or precise information about your location if you allows us (or a third party who provides it to us) to collect it. We may use this information to customize our response to your requests, such as to provide you with information about our products near you. We may also offer automatic (or "push") notifications to those who opt in to receive such notifications from us through their device or app settings. You do not have to provide location information to us or enable or disable push notifications to use any of our mobile applications. If you have questions about location information or notifications, please check the privacy settings of your device and/or contact your mobile service manufacturer or provider.
6. Your Choices
You can limit the collection of certain information and the communications we send to you. To opt out of receiving marketing emails, you may click the link labeled “unsubscribe” at the bottom of any of our marketing emails. Please note that even if you unsubscribe from marketing messages, we may still need to contact you with transactional information about your account such as order confirmations and shipping notices. You can also exercise certain choices with respect to interest-based ads as set forth above in the “Third Party Advertisers and Interest-Based Ads” section. Additionally, you may have rights that are further described in the next section.
7. Your Rights Under U.S. State Laws
If you are a resident of certain U.S. States, you may have certain rights with regard to your Personal Information under those states’ applicable consumer privacy laws, which include:
• Right to Correction. You may have the right to request correction of Personal Information that we maintain about you if you find that the Personal Information is inaccurate.
• Right to Deletion. You may have the right to request that we delete Personal Information that we have collected from you.
• Data Portability. You may have the right to request a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format.
• Right to Withdraw Consent. You may have the right to withdraw your consent to the processing of your Personal Information.
• Right to Limit Use and Disclosure of Sensitive Personal Information. You may have the right to limit the processing of your sensitive Personal Information.
• Right to Opt-Out. You may have the right to opt-out of certain uses of your Personal Information such as for (i) targeted advertising, (ii) “sale” or “sharing” for cross-context behavioral advertising, or (iii) profiling or automated decision-making activities that result in a legal or similarly significant effect on you. We do not engage in (iii), but you can opt-out of uses (i) and (ii) by adjusting your cookies settings to reject analytics and advertising cookies, noting that these adjustments may be specific to the Pernod Ricard site on which you make them. Additionally, if you visit our Sites with the GPC opt-out preference signal enabled, if required by law, that signal will be treated as a request to opt-out of “sale,” “sharing,” or targeted advertising. Please note your request may apply only to the browser or device from which you submit the request.
• Right to Appeal. In some circumstances, we may deny your request to exercise one of your privacy rights described in this Privacy Statement (e.g., if we cannot verify your identity). In such a case, we will communicate this in writing and explain the reasons for the denial. You may appeal our decision by responding to our denial email or submitting a request to PRUSAPrivacyRequest@pernod-ricard.com. We will notify you of our decision regarding your appeal in writing via an email from PRUSAPrivacyRequest@pernod-ricard.com within 45 days of receipt. If we deny your appeal, you may have the right to contact your state Attorney General to file a complaint.
We do not engage in profiling activities that further automated decisions producing legal or similarly significant effects; however, to the extent your Personal Information is ever used in that way, you additionally may have the right to opt-out of profiling activity that furthers an automated decision producing legal or similarly significant effects, and the right to information on profiling if any profiling is done for the purposes of an automated decision that produces legal or similarly significant effect, including to question the results of profiling, to be informed of the reason profiling resulted in a particular decision, to review your personal data that was processed for the purposes of profiling, to correct incorrect personal data processed for profiling and to have the profiling decision reevaluated accordingly.
Requests to exercise these rights may be made using the contact information listed at the end of this Privacy Statement, or as otherwise described in this section. Only you or, as permitted by law, a person that you authorize to act on your behalf, may make a request related to your Personal Information. For certain requests, we must verify your request before we can fulfill it. Verifying your request will require you to provide sufficient information for us to reasonably confirm that you are the person about whom we collected Personal Information or that the requestor is authorized to act on your behalf. We will not discriminate against you for exercising your privacy rights.
8. Information Security and Retention
We take all appropriate technical and organizational measures to protect the confidentiality and security of your Personal Information. We have 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 Personal Information consisting of credit card numbers and other payment information when processed for any transactions made on our Sites, as well as employing firewalls, site monitoring and other software intended to detect and prevent malicious activity.
We may retain your Personal Information for as long as your account is active, or as long as needed for the business purposes described in this Privacy Statement, in accordance with applicable legal standards. Please note that other recipients of your Personal Information who have been provided with such information in compliance with this Privacy Statement may retain your data for longer periods to fulfil the purpose for which your Personal Information was shared with them, or for their own compliance, dispute resolution, enforcement, or record management purposes.
9. Personal Information of People Under the Legal Purchase Age
Our Sites are intended only for adults who are of the legal age to purchase alcohol beverage products. 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.
10. Privacy Policies of Third Parties
This Privacy Statement only addresses the use and disclosure of information by Pernod Ricard. Third party Sites or platforms that may be accessible through our Sites have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy policies of those third parties before interacting with them and providing them with your information or taking part of any third party offer or promotion. If you interact with Us on social media platforms, those interactions are governed by the terms of use and privacy policies of the social media platform providers.
11. Sites Public Areas
Our Sites may provide public areas where you can publicly post information, such as reviews and comments. Prior to posting in these areas, please carefully read our Sites’ Terms of Use, available at https://www.pernod-ricard.com/en/locations/usa/pernod-ricard-usa-website-terms-use. All information you post in such public areas 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 publicly post your email address, you may receive unsolicited messages from others. Please use caution accordingly before posting any Personal Information in these public areas.
12. How to Contact Us
Please contact us if you have any questions at PRUSAPrivacyRequest@pernod-ricard.com.
13. Updates to this Privacy Statement and Supplemental Notice
Pernod Ricard reserves the right to modify, add, or remove portions of this Privacy Statement at its discretion and without prior notification. Any changes to this Privacy Statement will be posted on this Site, so please check back periodically.
SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
If you are a California resident, you have certain rights with regard to your Personal Information under the California Consumer Privacy Act of 2018, including the California Privacy Rights Act of 2020 and any regulations promulgated thereunder (the “CCPA”).
This section, which applies only to California residents, supplements the Privacy Statement and describes your rights under the CCPA, explains how you may exercise your rights, provides a notice of financial incentives, and provides an overview of the types of Personal Information we collect. If you have any questions about this section, please contact us at PRUSAPrivacyRequest@pernod-ricard.com or via the details listed under the Section titled “How to Contact Us” in the Privacy Statement.
Summary of Personal Information Processing and Disclosure
In the past 12 months, we have collected some or all of the categories of Personal Information described in the table below, which describes the business or commercial purposes for which the Personal Information was collected and the categories of third party entities with which such information has been disclosed to, shared with (for cross-context behavioral advertising), or sold to (as defined by CCPA) within the last 12 months. In addition, the categories of Personal Information described below may have been disclosed to public or governmental authorities where required by law.
| Categories of Personal Information | Purposes of processing | Disclosed for business purposes | Shared with or sold to |
|---|---|---|---|
Identifiers, such as name, alias, date of birth, postal address, email address, IP address, account name, and government-issued ID numbers. |
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Characteristics of protected classifications under CA or federal law, such as age and sex |
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Commercial and transaction information, such as products or services purchased or sold, obtained or considered or consuming histories or tendencies, or financial account information. |
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Internet or other electronic network activity information, such as browsing and search history and interaction with our websites, platforms, mobile applications and advertisements. |
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Audio, electronic, visual, or similar information, such as images, audio recordings, and video. |
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Inferences drawn from any of the above, such as characteristics or preferences. |
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Individual Rights for California Residents
As a California resident, you have the following rights under CCPA:
• Right to Know. You have the right to request that we disclose certain information to you about our collection, use, disclosure, or sale of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following: The categories of Personal Information that we have collected about you. The categories of sources from which such Personal Information is collected. Our business or commercial purpose for collection, use, or disclosure of such Personal Information. The categories of third parties with whom we sell or share such Personal Information.
• Right to Delete. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records unless an exception applies. For example, we may deny your deletion request if retention of the Personal Information is: Necessary to detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity; or prosecute those responsible such activities; For solely internal purposes reasonably aligned with your expectations based on your relationship with us; Necessary to comply with a legal obligations; or Otherwise necessary for internal use consistent with the context in which you provided the Personal Information.
• Right to Correct Inaccuracies. You have the right to request the correction of any Personal Information we maintain about you.
• Right to Opt-Out. You may have the right to opt-out of certain uses of your Personal Information such as for (i) targeted advertising, (ii) “sale” or “sharing” for cross-context behavioral advertising, or (iii) profiling or automated decision-making activities that result in a legal or similarly significant effect on you. We do not engage in (iii), but you can opt-out of uses (i) and (ii) by adjusting your cookies settings to reject analytics and advertising cookies, noting that these adjustments may be specific to the Pernod-Ricard site on which you make them. Additionally, as noted in our Privacy Statement, if the Global Privacy Control opt-out preference signal is enabled on your browser, that signal will be treated as a request to opt-out of “sale,” “sharing,” or targeted advertising for the browser or device where the Global Privacy Control is enabled. We do not sell or share the Personal Information of minors under 16 years of age; our Sites is not intended for those under 21 years of age, as that is the legal age to purchase alcohol beverage products in the United States.
• Right to Nondiscrimination. You have the right to not receive discriminatory treatment for exercising your CCPA rights. If you choose to exercise any of your CCPA rights with Pernod Ricard, we will not deny you goods or services, charge you with different prices or rates for goods or services (including through discounts, benefits, or imposition of penalties), or provide you with a different level of service than you would receive if you chose not to exercise such rights.
Exercising your CCPA Rights
You can submit your request to exercise your CCPA rights through any of the following methods:
• By email, at PRUSAPrivacyRequest@pernod-ricard.com;
• By calling our toll-free phone number, at (855) 652-0855; or
• By submitting a request form online, at https://prusaccpa.zendesk.com/hc/en-us/requests/new.
After submitting a request, we will take steps to verify your identity in order for us to properly respond and/or confirm that it is not a fraudulent request. In order to verify your identity, we will request, at a minimum, that you provide your name, email address, phone number, address, and relationship to us, so that we can seek to match this information with the information existing in our systems. When providing Us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify that the consumer submitting the request is the same individual about whom we have collected personal information, we may contact you for more information, or we may not be able to meet your request. Only you, or an agent legally authorized to act on your behalf, may make a verifiable request related to your Personal Information. If you are making a request as the authorized agent of a California consumer, we will ask you also submit reliable proof that you have been authorized in writing by the consumer to act on such consumer’s behalf. We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, the CCPA allows us up to 90 days to respond. We may contact you within 45 days from the date you contacted us to inform you if we need more time to respond.
Other California Resident Privacy Rights
Under California Civil Code Section 1798.83 (the “STL”), California residents that we have an established business relationship with are entitled to request and receive, free of charge and once per calendar year, information about certain Personal Information we have shared, if any, with other businesses for their own direct marketing uses in the previous calendar year. To make a request under the STL, please contact us at PRUSAPrivacyRequest@pernod-ricard.com.
Please note that not all Personal Information sharing may be covered under the California STL and only covered Personal Information sharing will be included in our response.
Notice of Financial Incentive
Pernod Ricard may offer consumers incentives for providing their Personal Information to us, including to provide discounts on our products (“Incentives”). We collect, share, and retain Personal Information about consumers as part of their participation in receiving these Incentives, which may be considered financial incentives under the CCPA. The value of your Personal Information to us relates to costs associated with making the Incentives available to consumers, such as IT, administration, direct costs, third party costs, and service development costs.
Your Personal Information is collected and retained, and may be shared with third parties as described in our Privacy Statement including in order to (i) administer the Incentives, (ii) for research and analytics purposes, (iii) improve our products and services, (iv) to better reach you with more relevant, targeted ads and offers in-store, online, and on third party sites and platforms, and (v) send you news, updates, and offers by email, postal mail, and text message (in accordance with your communications preferences).
To participate in receiving Incentives, you must opt in by providing us with certain Personal Information, which can include your name, email address, and contact information. You may opt out of receiving Incentives at any time by contacting us at PRUSAPrivacyRequest@pernod-ricard.com.