Under data protection law, we can only use your Personal Data if we have a proper reason for doing so, e.g.:
• to comply with our legal and regulatory obligations;
• for the performance of a contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests or those of a third party; or
• where you have given consent.
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 register or sign-up via our Digital Services: the Personal Data you give is used to provide you with the benefits that typically come along with registration. This includes information on the products and brands that you have signed up to (and, if you have opted-in, to receive information about other Pernod Ricard products), the ability to send, receive and personalise communications you select at the time of registration or that automatically come with your registration. For example, subscription to a newsletter, creation of an account, participation in a sweepstake or contest, invitation to or attendance at an event organised by us or on our behalf;
• When you are selected or invited to attend an event we will use your Personal Data to provide you with details, tickets and entry information and to provide the organisers with information to allow them to verify your attendance;
• When you enter a sweepstake or contest we use your Personal Data to identify unique entrants and to inform winners and others of the outcome;
• When you use the ‘Send to a friend’ feature: Personal Data for one-time use (typically, names and email addresses) is used only once (e.g., to send a message) and is not retained by us;
• When using e-commerce on some of our websites: we (or a third party on our behalf) will use your Personal Data to create your account, facilitate the purchase process, manage your order and deliver your products under the contract you have with us (or the third party) and to understand your purchase history. We may use automated decision making to detect fraudulent activity or to secure payment by verifying card-holder details where it is necessary for entering into or performing a contract with you;
• When you use a QR Code or equivalent feature displayed on our products: we use your Personal Data to send you more information on the products where the QR code or equivalent feature was displayed or other Pernod Ricard products (if you opt-in to receive that information);
• When you submit Personal Data on the iPads or other mobile devices available in Heritage Centres or distilleries: this is used to send you more information on the relevant products;
• Feedback, questions, or comments through our ‘Contact Us’ form and our ‘Tell Us’ compliance reporting system: if you contact us via an online contact form, your information is used to respond to your inquiry or comment;
• Display targeted ads about Pernod Ricard’s products and services on the social media you are registered on and measuring ad performance. If you do not object to the use of your Personal Data for targeted advertising purposes, we will pass on your identification data (hashed) to the social media whose marketing tools we use (see section 5 below), that is to say your surname, first name, contact details and date of birth. Subject to your consent, social media can also identify you through the cookies placed on our Digital Media. Once your data is shared on social media, it is used to enable such media, at your initiative, to find you among other users, and (i) to show you ads about our products and services when you browse the relevant social media, and (ii) to identify, based on your profile on the relevant social media (where you live, age, gender, language, socio-demographic characteristics, interests and behavior), lookalikes who may also be interested by Pernod Ricard’s ads. Social media also provide us with reports on the results of our advertising campaigns (click-through rate, conversion rate, audience profile, etc.) to enable us to improve our future campaigns. In the context of these activities, we act as a joint controller together with each social media. We do not, however, collect or access at any time the Personal Data concerning you held by the social media concerned and relating in particular to your profile or your behavior on such social media. This type of Personal Data processing is based on our legitimate economic interest in offering relevant advertising content on social media, tailored to a specific audience.
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:
• Ensuring that we are as efficient as we can be so we can deliver the best Digital Service and products for you that we can and understanding our customers and the users of our Website;
• To allow us to provide bespoke Digital Services and products where requested by you, to personalise your experience and to tailor the content, offers and promotions we send to you promoting our products and services;
• Protecting our commercially valuable information and also our intellectual property;
• Preventing and detecting fraud and/or criminal activity that could be damaging for us and for you;
• Understanding how our business is performing and considering how to improve our performance; and
• Ensuring we are able to keep up to date with our customers and contacts and developments in their organisations.
Promotional communications
We may use your Personal Data to send you updates (by email 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:
• contacting us at ukconsumerfeedback@pernod-ricard.com
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
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.