Privacy Policy

We take your privacy very seriously and we respect your right to privacy 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 supervisory authorities in the event you have a complaint.

"We", "us" and "our" refer to Chivas Brothers Limited, Pernod Ricard SA and Pernod Ricard SA's affiliates (these affiliates are collectively referred to as the "Pernod Ricard Group").. A list of the affiliates that we refer to in this privacy policy can be found at this link.

We collect, use and are responsible for certain Personal Data about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as 'controller' of that Personal Data for the purposes of those laws.

Before using our Digital Services, please read this Privacy Policy. If you do not agree to this Privacy Policy or our Cookies Policy, please do not use our Digital Services.

We are the data controller when processing your Personal Data in 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").

1. What Personal Data do we collect about you and how?

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:

This Personal Data is required to provide products and Digital Services to you. If you do not provide Personal Data we ask for, it may delay or prevent us from providing products or services to you.

2. How your Personal Data is collected

Personal Data we collect from you

We collect most of this Personal Data directly from you—in person, by telephone, text or email and/or via our website and apps. This usually occurs when you take part in one of our promotional activities or subscribe to one of our Digital Services, for example:

The type and amount of information we collect for the features listed above will vary and depends on the activity.

Personal Data we collect from other sources

We may also collect information:

We may occasionally purchase the contact details of people who might be interested in hearing from us. Before purchasing such information, we will check the wording used when your information was originally collected, to make sure that we only contact people who have actively expressed an interest in receiving information from third parties.

We may also receive information if you have provided permission to other organisations to share it with us. Before providing permission to such third party organisations to share your personal information, you should check their privacy notices carefully. Subject to applicable laws, we may use a variety of technologies that collect and provide information about how our Digital Services are accessed and used by you. We may also use demographic information about who uses our Digital Services, which we get from third parties such as Google or social media that you use (we call this "Usage Information").

Usage Information may consist of the pages you have visited, the time you visited them and which beverage information (or other content) you accessed or provided. It also includes which language you use, demographic information about you (such as your age, gender and interest areas, where available) and which pages you have visited before you visited the current page.

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.

How and why do we use tracking technologies?

We use tracking technologies such as cookies, IP address recording or log files, to gather technical information such as your web browser type and which operating system you use, the webpage you came from, your path through our website and your Internet Service Provider. This is so we can improve the functionality of our websites and better understand how visitors like you use our Digital Services and the tools they offer.

Often, individuals will interact with us in multiple ways and will provide us with personal information in different contexts. We may use your personal information to obtain a profile of your different interactions with us and to understand your preferences.

These tracking technologies help us tailor our Digital Services to your personal needs:

3. For what purpose do we use your Personal Data?

Under data protection law, we can only use your Personal Data if we have a proper reason for doing so, e.g.:

Generally, the information we collect is only used for any purpose for which you submitted it to us, for any purpose made clear to you at the point it was collected or here in this Privacy Policy. These purposes may include:

When you submit your Personal Data, you may also be given the option (through a tick box or other consent mechanism) to have your information used for an activity or service different from the one you are requesting. For example, if you enter a contest to win a prize, you may also be invited to sign up for a newsletter about other products. If you choose to have your information used for another activity or service in this way we will use your information to provide them to you.

In addition, when you submit your Personal Data, you may be given the option (through a tick box or other consent mechanism) for your information to be used for other Pernod Ricard products. If you choose this option we (and other Pernod Ricard Group affiliates) will use your information to provide you with information and promotions regarding other Pernod Ricard products.

We may also use your email address to send you transactional or administrative communications such as confirmation emails when you sign up for, or unsubscribe from, a specific registration or activity. We may also use it for certain service-related announcements, such as updates to our Privacy Notice, discontinued features or programs on our Digital Services, changes to our online services or technical support policies.

We retain your personal data in our global consumer database which allows us to ensure that your Personal Data remains accurate and up to date and to share your Personal Data with appropriate Pernod Ricard group affiliates. To avoid duplication in our database, we may use information about each of your interactions with one of our Pernod Ricard Group affiliates to check whether your Personal Data is still accurate. We will use that information to complete, enhance or update your Personal Data with the additional information you might have provided.

Subject to applicable laws, this may include occasionally combining, updating, or otherwise enhancing the Personal Data collected through our Digital Services with anonymised data we get 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) not linked to any personal information about you with Personal Data collected in other cases (such as during account registration).

We may also use your Personal Data, the combined information referred to above and/or demographic information for our internal marketing, segmentation, analysis and demographic studies. This helps us to constantly improve, personalise, and customise the products and services we provide.

Legitimate interests - managing our business

In relation to a number of uses of Personal Data we refer to above we are doing this on the basis that it is in our legitimate interests – or those of a third party – for us to do so. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. These interests cover a number of aspects of our business operations, namely:

Promotional communications

We may use your Personal Data to send you updates (by email, text message, telephone or post) about our products and Digital Services, including exclusive offers, promotions or new products and Digital Services.

We have a legitimate interest in processing your Personal Data for promotional purposes. This means we do not always need your consent to carry out promotional activities. However, where consent is needed, we will ask for this consent separately and clearly.

You have the right to opt out of receiving promotional communications at any time by:

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or Digital Services in the future, or if there are changes in the law, regulation, or the structure of our business.

4. What happens if you do not wish to share your Personal Data with us?

If you choose not to submit any Personal Data when requested, you may not be able to participate in certain activities or use some of the personalised features of our Digital Services. This may also limit the services and special offers we can provide you. For example, if you refuse to share your email address, you will not be able to receive any of our newsletters or otherwise register for our Digital Services. However, you do not need to give us any Personal Data to simply browse our websites and learn more about us and our products.

5. Who do we disclose your Personal Data to and why?

We will never share your Personal Data with any third party that intends to use it for direct marketing purposes, unless we have specifically told you and you have given us explicit permission to do this.

We may share your Personal Data with affiliates within the Pernod Ricard Group. The purposes are explained in Articles 2 and 3 above. The information we collect as described in this Privacy Policy may come from the entity to which you provide it but may also be made available, subject to your consent, through such entity to other affiliates of the Pernod Ricard Group to provide you with news and promotional information about their products or programs you have shown interest in.

If you wish to withdraw your consent to such sharing and use of your information, please address your request as indicated in Article 9 of this Privacy Policy. Please tell us if you are withdrawing your consent for us to share your Personal Data with all of the affiliates in the Pernod Ricard Group to provide you with news and promotional information or just some of those affiliates (and, in that case, please indicate which ones).

We may also share your Personal Data with other third parties, but only in the following circumstances:

When we run a promotion in partnership with a third party outside the Pernod Ricard Group, we may provide a separate link to their privacy policy which you should read before you share any Personal Data. The operators of other sites may collect information from you which will be used by them in accordance with their own data protection policy or privacy policy. If you do not want your information to be collected by or shared with a company other than the Pernod Ricard Group, you can choose not to opt in or participate in these events at the time the Personal Data is collected or requested;

6. Is your Personal Data sent to recipients located in other countries and why?

We and our affiliates in the Pernod Ricard Group are a global group and your Personal Data may be transferred across international borders. It may be transferred to countries that have different data protection laws to 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, ensure the transfer complies with data protection law both during transit and at the storage location and all Personal Data will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission. You can check here for a list of countries where we have an affiliate within the Pernod Ricard Group that may receive your Personal Data.

Our main service providers for the operation of our Digital Media are based in the United States. The transfers of personal data to these services providers are implemented in accordance with applicable laws and rely on standard contractual clauses as set out by the European Commission or on the EU-US Privacy Shield. Such service providers are also bound by a contract that ensures a high standard of privacy protection and requires (amongst other provisions) that they act only on a member of Pernod Ricard Group's instructions and implement 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 retain your Personal Data as long as your account is active, for the duration of a contract with you or however long it takes to provide you with the products or services requested, to answer queries or resolve problems, to show that we treated you fairly, to keep records required by law and to improve or offer new services.

We may also need to retain your Personal Data to comply with our legal and regulatory obligations, resolve disputes, enforce our agreements, and similar records management purposes.

We may also retain your Personal Data for a reasonable period after you stop using our services or our Digital Services. After this period, your Personal Data will be deleted from all systems in the Pernod Ricard Group.

If you ask us to delete your information in accordance with your rights set out in Article 9 below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future.

8. How do we keep your Personal Data secure?

We have appropriate security measures to prevent your Personal Data from being accidentally lost, or used or accessed unlawfully. These include: (i) storing your Personal Data in secure operating environments that are not available to the public and that are only accessible to authorised employees, our agents and contractors; and, (ii) verifying the identities of registered users before they can access Personal Data we store about them.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

9. Your rights

You have the following rights, which you can exercise free of charge:

You can ask us to:

You can object:

If your Personal Data has been processed on the basis of your consent, you can withdraw your consent at any time. We hope that we can resolve any query or concern you may raise about our use of your information. You also have the right to complain to the supervisory authority in the European Union where you work, normally live or where any alleged infringement of data protection laws occurred.

If you would like to exercise your right to object to direct marketing please email us on contactus@chivas.com.

If you would like to exercise any of your other rights, please email us on chivasbrothersdataprotection@pernod-ricard.com

Your objection (or withdrawal of consent) may mean we cannot provide the products or services you have requested of us or you may not be able to use the services we offer. We will advise you where this is the case. In certain circumstances even if you withdraw your consent we may still be able to process your Personal Data if required or permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and regulatory obligations.

If you participated in a program that involved a third party and you agreed to receive communications from that third party, you will need to contact them directly to opt-out. This process should be outlined in the third party's privacy policy.

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 our 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. Do we link to other third party websites?

Our Digital Services may contain links that will direct you to other websites or services that are operated and controlled by third parties. This includes links from advertisers, sponsors and partners that may use our brands or logo(s) as part of a co-branding agreement.

The operators of other sites may collect information from you which will be used by them in accordance with their own data protection policy or privacy policy. We have no control over these third parties, and your use of their websites and features are subject to the privacy policies posted on those websites. We are not responsible or liable for the privacy practices or business practices of any third-party website. Therefore, you should exercise caution and review the privacy policies applicable to those external websites you visit, before you provide your Personal Data.

12. How can you contact us?

If you have any questions, complaints, or comments about this Privacy Policy or our how we collect and manage your Personal Data, please contact us either:

- by writing to: Data Privacy Champion, Chivas Brothers Limited, Kilmalid, Stirling Road, Dumbarton G82 2SS, or sending an email to: chivasbrothersdataprotection@pernod-ricard.com

- or by writing to: Data Protection Officer, Pernod Ricard SA, 12 place des Etats-Unis 75783 Paris Cedex 16

13. Changes to this Privacy Policy

This privacy notice was last updated: May 2018. We may change this privacy policy from time to time, so please check back regularly to keep informed of updates to this Privacy Policy and our Cookies Policy.