PRIVACY POLICY

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Irish Distillers, in its role as Data Controller, respects your right to privacy when you use our digital media (such as our websites, our mobile applications, our pages on the social network, any online forms to register for our events (“Digital Media”) and communicate electronically with us. The purpose of this Privacy Policy is to inform you how Irish Distillers Ltd, a company registered in Ireland with company number 23732 and having its registered office at Simmonscourt House, Simmonscourt Rad, Ballsbridge, Dunlin 4 (“Irish Distillers”, “we,” or “our”) collect, store, use and process your Personal Data provided through any Digital Media operated by Irish Distillers. 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. To whom do we disclose Your Personal Data 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 secure your Personal Data? 9. What are your rights regarding Personal Data? 10. How do we process children’s Personal Data? 11. How can you contact us or lodge a complaint to the relevant Supervisory Authority? 12. Changes to our Privacy Policy 1. What Personal Data do we gather about you and how do we collect it? We collect and process personal data relating to you in connection with your use of our Digital Media. This personal data may include: • your name and contact details, including your address, phone number and email address; • your age; • your credit/debit card or bank account details; • your IP address; • any other information relating to you that you provide to us or that we generate about you in connection with your use of our Digital Media. Subject to applicable law requirements, we may use a variety of technologies that collect and provide information about how our Digital Media is accessed and used by you. We may also use demographic information about the users of our Digital Media, 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. 2. How and why do we use tracking technologies? Irish Distillers uses tracking technologies such as cookies, IP Addresses or Log files. Tracking technologies help us tailor our Digital Media to your personal needs. • We use Cookies to better understand how visitors use our Digital Media and the tools and services offered, and improve their use and functionality. Subject to your consent where required by applicable law, our Digital Media 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 Media 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 our Cookie 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 Internet Protocol (IP) addresses to (among other things): (i) troubleshoot technical concerns, (ii) maintain website safety and security, (iii) restrict access to our Digital Media to comply with applicable law or contractual restrictions, and, (iv) better understand how our Digital Media 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 Media 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 Media, and which pages they've viewed on our Digital Media 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? We collect information about you to: • Enable you to use our Digital Media: when you register with or sign-up to our Digital Media, 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 accompany your registration (e.g. receiving the communications you select at the time of registration, being invited to events, participating in a sweepstake, etc.); • Enable you to purchase products on our websites: we use your Personal Data to manage your order and deliver your products. We can also implement technical solutions to detect fraudulent payment and secure the payment of your purchases on our websites. • Respond to your questions and comments: if you contact us via an online contact form, such as our “Contact Us” form or through our “Tell Us” compliance reporting system, your Personal Data is used to respond to your query or comment. • 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 Media, changes to our online services or technical support policies, or other related changes) • Send you promotional and marketing information, subject to any preferences that you express when we collect your contact details or subsequently: • 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 Media 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. You can opt out of receiving promotional and marketing materials from us at any time by contacting idpr-privacy@pernod-ricard.com; • 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; • When you use a QR Code or equivalent feature displayed on Irish Distillers 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. • Improve and develop our Digital Media; • Generate and analyse statistics of regarding usage of our Digital Media; and • Prevent, investigate and detect fraud. The legal bases on which we process your personal data are: • That this is necessary for the performance of our contract with you, or to take steps prior to entering into a contract with you; • That this is necessary for compliance with a legal obligation that applies to us; • that this is necessary for the purposes of our legitimate interests or the legitimate interests of a third party: We, and/or the third party will only process your personal data for the purposes of our/their legitimate interests where we are of the view that to do so would not constitute an unwarranted interference with your own interests or fundamental rights and freedoms. The legitimate interests for which we process your personal data include our legitimate interests in: o conducting our business in a responsible and commercially prudent manner; o promoting our products and services; and o pursuing our corporate and social responsibility objectives. • In certain circumstances, that you have given your consent to the processing. Profiling and Automated Decision Making We may conduct profiling based on monitoring your browsing activities on our Digital Media 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 Article 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 Media services and special 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 Media. However, to simply browse our Digital Media and learn more about Irish Distillers 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. To whom do we disclose your Personal Data and why? • Within the Irish Distillers Group Irish Distillers may share for the purposes mentioned in Section 3 your Personal Data within the Irish Distillers Group, including its affiliates worldwide. • With third parties Irish Distillers 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 Media 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 Irish Distillers 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 Irish Distillers; • For joint and co-sponsored programs and promotional purposes: When we run a joint or co-sponsored program or promotion on our Digital Media 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 Irish Distillers 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, or if in our good faith judgment, such action is reasonably necessary to comply with legal processes, to respond to any claims, or to protect the safety or rights of Irish Distillers, its customers, or the public; • In the event of a merger or acquisition of all or part of Irish Distillers by another company, or in the event that Irish Distillers were to sell or dispose of all or a part of the Irish Distillers business, the acquirer would have access to the information maintained by that Irish Distillers 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? Irish Distillers is a global company and your Personal Data may be transferred outside the European Economic Area (EEA), including to a country which has a different level of data protection than the one existing in the country from where you submitted your Personal Data. If and to the extent that your Personal Data is transferred outside the EEA, Irish Distillers will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers. These may include entering into a contract governing the transfer that contains the ‘standard contractual clauses’ approved for this purpose by the European Commission or, in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework. If you would like to receive further details of the measures that we have taken in this regard, please contact us at idpr-privacy@pernod-ricard.com. 7. How long do we keep your Personal Data? We will store the Personal Data that you sent us via our Digital Media 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 our internal retention procedure as necessary to comply with our legal and regulatory obligations, resolve disputes and enforce our agreements. We may thus retain your Personal Data after you stop using Irish Distillers services or our Digital Media according to the statute of limitations. 8. How do we secure your Personal Data? Irish Distillers 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. 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 Irish Distillers 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. 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. • 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 Irish Distillers. Irish Distillers will take reasonable steps to inform the other entities of the Irish Distillers 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 Irish Distillers 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 Irish Distillers 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 Irish Distillers 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 Irish Distillers. • 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. 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 we treat children's Personal Data? Our Site is not intended for children under the legal drinking age (“Minor”), 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 notified or learn that a Minor has submitted Personal Data to us through our Digital Media, we will delete such 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 us by writing to: Irish Distillers Simmonscourt House Simmonscourt Road Ballsbridge Dublin 4 Ireland or sending an email to: idpr-ricard@pernod-ricard.com You are informed that you can also lodge a complaint with the Supervisory Authority of the country where you are located if you have any concern about the conditions of processing of your Personal Data by Irish Distillers. 12. Changes to our privacy policy We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was last updated in May 2018.