The Absolut Company 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 to our events…) and communicate electronically with us.
1. What Personal Data do we gather about you and how?
Personal Data is collected only for the purposes set out in Section 3 below and with your informed knowledge (i.e., when you knowingly provide it to us through one of the online forms available on our Digital Media) through various touch points, each time you participate in any of the features or services offered by our Digital Media, as they may evolve from time to time including without limitation:
The types and amount of information collected for the features listed above will vary depending on the activity. The requested Personal Data will include your identification information as well as certain information related to your personal life and center of interests (depending on the activities you participate in).
2. How and why do we use tracking technologies?
TAC uses tracking technologies such as cookies, IP Address or Log files, to gather certain information such as browser type and operating system, referring page, path through site, domain of ISP etc. for the purpose of improving the use and functionality of our websites and to better understand how visitors use our Digital Media and the tools and services offered on it. Tracking technologies help us tailor our Digital Media to your personal needs.
3. For what purpose do we use your Personal Data?
These purposes are mainly the following:
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 and it may happen that our Digital Media 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 our newsletters or otherwise register on our Digital Media. However, to simply browse our Digital Media and learn more about TAC 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 are necessary in order to benefit from a service.
5. Who do we disclose your Personal Data to and why?
TAC will never share your Personal Data with any third party that intends to use it for direct marketing purposes unless we have specifically informed you beforehand and you have given us specific permission to do this.
TAC may also share your Personal Data with third parties, but only in the following circumstances:
6. Are your Personal Data sent to recipients located in other countries and why?
TAC is a global company and your Personal Data may be transferred across international borders. It may be transferred to countries that have a different level of data protection laws than the one existing in 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. TAC takes the appropriate measures to maintain security of the Personal Data both during transit and at the receiving location by implementing contractual clauses as set out by the European Commission, in accordance with applicable law requirements. You may consult the list of countries where TAC has an affiliate likely to receive your Personal Data by clicking here.
Our main service providers for the operation of our Digital Media are based in the United States. The transfer 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 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 TAC instructions and implements all technical measures necessary on an ongoing basis to keep your Personal Data secure. You have a right to obtain details of the mechanism under which your information is transferred outside of the EEA by email@example.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, as we have a 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 need that your Personal Data be retained then after 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 TAC services or our Digital Media. Other recipients of your Personal Data described in Article 5 may retain your Personal Data for a longer period where doing so is necessary to fulfil the purpose for which you allowed us to share your Personal Data with them, or for their own compliance, dispute resolution, enforcement, or record management purposes as provided by applicable law.
Retention periods applicable to Cookies and other trackers are further detailed in the Cookies Policy.
8. How do we keep your Personal Data secure?
TAC 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 TAC 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. How you can you exercise your rights regarding the use of your Personal Data?
You can contact your local usual contact (the Legal Department or Local Privacy Champion, if any) or Pernod Ricard Group Data Privacy Officer to express the following choices:
If you do not want to receive newsletters, announcements, or other communications and/or services from our Digital Media, please do not opt-in for those communications or services at the time of registration. If you have opted-in and, at a later time, wish to opt-out, please click on the unsubscribe link inserted in our communications.
Along with every e-mail communication sent to you, we provide you the opportunity to discontinue receiving future communications (i.e., unsubscribe). Simply follow the unsubscribe process or directions provided in the email.
When exercising your rights, you may be asked for a duly signed proof of identity.
TAC will not process Personal Data involving automated decision making, unless if necessary 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 in such case, you will be informed through layered notices on the conditions of processing of your Personal Data, the profile built, how the profile is used, the logic involved. You will be requesting to explicitly consent to such profiling, if it is not necessary for the performance of a contract.
Please note that the automated tools used are regularly checked to ensure that the Personal Data processing is made 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 contest the result of the automated decision by sending an email to the contact details in Article 12 below.
10. How we treat children's Personal Data?
11. Do we link to other third party websites?
Our Digital Media 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 logo(s) as part of a co-branding agreement. We have no control over these third parties, and your use of their websites and features are subject to their privacy policies posted on those sites. 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 the external websites you visit before providing your Personal Data.
12. How can you contact us or the relevant Supervisory Authority?
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 The Absolut Company.
Last Update: 17 February 2018