POWERS and Pernod Ricard USA are affiliates within the Pernod Ricard family of brands (hereinafter "We" or "Us" or "Our"). We respect your right to privacy. We have developed this Privacy Statement to inform you how we handle the Personal Information you provide to us.
We may update this Privacy Statement from time to time. If we make any material changes to this Privacy Statement, we will notify you by sending a notice to the primary email address provided to us or by posting the revised Privacy Statement on our website.
Last Updated: October 2018
- What types of Personal Information do we collect and how do we collect it?
- How do we use your Personal Information?
- When is your Personal Information disclosed to others?
- Cookies and Other Data Collection Technologies
- Mobile Applications
- Your Choices
- Access, Correction, and Other Rights
- Information Security and Retention
- European Union and International Privacy Matters
- Personal Information of People Under the Legal Age
- Privacy Policies of Third Parties
- Forums and Other Public Areas
- How to Contact Us
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, country of residence, 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 Us including your purchase history, customer account information.
- Usage Information about how you use Our] websites and mobile applications, 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 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.
We use your Personal Information to:
- Fulfill your orders for products or services and for related activities, such as send you communications related to your order, respond to your inquiries, 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 surveys and other 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; 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.
If We intend to uses your Personal Information in a manner materially different than as set out in this Privacy Statement, We will provide you with information on that other purpose prior to that use.
We understand that you do not want us to provide your Personal Information directly to third parties for their own marketing purposes without your consent. We limit our sharing of your Personal Information as follows:
- 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.
- 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 unaffiliated 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 may also 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 i.e. Personal Information in an aggregate form that no longer identifies you.
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.
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 devices 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.
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, referring 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 US 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
We have 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 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.
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.
While we do 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 www.allaboutdnt.org.
We offer 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 Us. You do not have to provide location information to Us 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. We may also collect information from mobile applications in the same manner that we do from websites.
You can always limit certain information you provide to Us
You can also limit the communications that We send to you. To opt-out of emails, simply click the link labeled “unsubscribe” at the bottom of any email we send you. 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.
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.
You may request that we delete your Personal Information from our active records. We will make reasonable efforts to honor such requests, provided that, we may retain archived information and are unable to remove your Personal Information from the records of any third parties with whom the information has previously been shared in compliance with this Policy Statement. Please contact us with any such requests.
We respect 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.
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 it is being collected and transmitted over the Internet as well as firewalls, site monitoring and intrusion detection software.
We 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. 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.
This section describes the additional commitments that apply to your Personal Information if you are located in the European Union and your data is processed by Brand or PR USA outside the European Union, or if your data is processed by a Brand established in the European Union:
- We will use your Personal Information as described in this Privacy Statement as necessary (i) for the performance of any contract between you and Us, where you have made a purchase, including in order to process your payment, make a delivery, respond to any customer service requests, (ii) with your consent where required by law, for instance to send you marketing communications or administer surveys and other promotional events, (iii) to comply with our legal obligations, notably in terms of payment processing, financial account management, fraud prevention, legal compliance, and (iv) to further our legitimate interests including our legitimate interest in better serving you and improving our services, improving our communication with you, and ensuring the accuracy of the information we hold about you.
- Where our processing of your Personal Information listed above is not based on your consent or our legitimate interests (i.e. is necessary for the performance of a contract or required to fulfil our legal obligations), failure to provide any of the requested Personal Information may result in us being unable to process your order or respond to your request, and certain features of our website and/or application may not be available.
- We will seek your consent to use and process your Personal Information when required to do so by applicable law. In such case, you may withdraw such consent at any time by contacting usor opting out where applicable.
- We may conduct profiling activities based on your interests and your browsing on our web sites to better serve you and provide you with targeted marketing information on our products in accordance with your tastes. You may opt out at any time when receiving such information. We respect your right to restrict or object to the processing of your Personal Information, as well as your right to data erasure and portability. To exercise these rights, please contact us. You also have the right to lodge a complaint with the competent supervisory authority.
- We will always protect the privacy and security of your Personal Information in accordance with this Privacy Statement as well as with any applicable laws, regardless of where it is processed or stored.
- We will keep your data as long as required by applicable law for the purpose for which the data was collected.
- The categories of data recipients include, but are not limited to our marketing departments and relevant services providers (not namely mentioned) depending on the purposes of the data processing. Such recipients of your Personal Information may be located outside of the EU. Therefore, where we transfer your Personal Information to a country that may not present an adequate level of protection according to EU law, we may rely on contracts based on the European Commission's standard contractual clauses. If you would like more information on these contracts, please contact us.
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.
This Privacy Statement only addresses the use and disclosure of information by Us. 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.
Please contact us if you have any questions or comments about our privacy practices or this Privacy Statement. You can always reach us online at email@example.com. You can also reach us via mail to:
Cassie Ostle – Legal Manager