PRIVACY POLICY

The purpose of this “Privacy Policy” is to inform you about how The Absolut Company AB, a corporation duly organized under the laws of Sweden, with its registered address at S-117 97 Stockholm, Sweden (visiting address: Marieviksgatan 19C S-117 43 Stockholm, Sweden) and its affiliates (together “We”, “Us” or “Our”) collect, store, use and process your personal data (“Personal Data”) provided through any digital media operated by Us (“Digital Media”).

We, in Our role as data controller, respect your right to privacy when you use Our digital media (such as Our websites, Our mobile applications, Our social media pages, and any online registration forms for Our events) and communicate electronically with Us.

  1. What Personal Data do We gather about you and how do We collect it?

Personal Data is collected only for the purposes set out in Section 3 below and each time you use any of the features or services offered by Our Digital Media.

The types and amount of information collected when using the above-mentioned features and services may be updated and vary depending on Our activities.

Most of the Personal Data We process is collected directly from you, in particular whenever you fill out a form on Our Digital Media or contact Us. We also collect, with your consent, Personal Data concerning you whenever you browse Our Digital Media through the use of tracking technologies (in this respect see section 2 below as well as Our Cookie Policy).

Subject to requirements under the applicable laws, We may also use various tools that allow Us to target the ads We display on social media. Your identity, contact and social media information (i.e. your profile data, social demographics, behavioral data and interests) are processed in this context.

  1. How and why do We use tracking technologies?

We use tracking technologies such as cookies, IP addresses or log files. Tracking technologies help Us tailor Our Digital Media to your personal needs and offer you content adapted to your interests.

  • Cookies are small files that are placed on your device that serve a number of purposes such as letting you browse between pages efficiently, remembering your preferences, and generally improving your experience. We use cookies to better understand how visitors use Our Digital Media and the tools and services offered, improve their use and functionality, and provide you content adapted to your interests. Subject to your consent where required by applicable law, Our Digital Media use cookies and similar technologies. The use of cookies on Our Digital Media allows you to enjoy more seamless visits and more accurately measures your behavior on Our Digital Media. You can learn more about the cookies We use and how you can disable cookies through Our Cookie Policy.
  • An Internet Protocol (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 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 log files that record activity on the Digital Media and gather statistics about users’ browsing habits. These entries are generated anonymously and help Us gather information such as (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 files 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.
  1. For what purposes do We use your Personal Data and on what legal grounds?

We may collect information about you to:

  • Comply with a legal or regulatory obligation.
  • Respond to your request for service or for the performance of a contract:When you register or sign up for 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 along with your registration (e.g. being invited to events, participating in a contest, etc.);

    When you purchase products on Our websites: your Personal Data is used to manage your order and deliver your products;

    When you leave questions, feedback, or comments: your Personal Data is used to respond to your inquiry or comment if you contact Us via an online contact form; or

    To 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).

  • Allow Us to send you marketing information when you consent:Signing up for promotional information: your Personal Data may be used to send you announcements and promotional information by email or text message if you have signed up for it. For example, when you sign up for a contest or other promotion, you may also be invited to sign up for a newsletter or alerts from Our Digital Media hosting the promotion or from other websites;

    Using the “Send to a friend” feature: your Personal Data is used only once to send the communication and is not further retained by Us unless required to do so by law

    Scanning a QR Code or equivalent feature displayed on Our products: We use your Personal Data to send you more information on the products displaying the QR code or equivalent feature or concerning other products; or

    This type of Personal Data processing is based on Our legitimate economic interest in offering on social media, tailored to a specific audience.

  • Fulfil Our legitimate interest in better serving your needs:Whenever this new processing is compatible with the data processing that you have consented to, We may occasionally combine, update, or otherwise enhance the Personal Data collected through Our Digital Media with data We receive 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, etc.) not linked to other Personal Data about you with Personal Data collected though Our offers (such as during account registration); or

    We may use the combined information and/or demographic information for Our internal marketing and demographic studies and to constantly improve, personalize, and customize the products and services We provide you to better meet your needs.

  • Fulfil Our legitimate interest in offering relevant advertising content, tailored to a specific audience: social media services may 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 (location, age, gender, language, socio-demographic characteristics, interests and behavior), others who also may be interested in Our products and services. 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 platform. We do not, however, collect or access at any time the Personal Data concerning you held by the social media platform concerned and relating in particular to your profile or your behavior on such social media.

We will ensure that your Personal Data remains accurate and up-to-date and avoid duplication in Our database, by verifying each of your interactions with Us and/or one of Our affiliates to ensure your Personal Data is still accurate or needs to be completed or updated with the additional information you have provided.

We may engage in automatic profiling based on your browsing activities on Our Digital Media to better understand your preferences and center of interests and adapt Our marketing communications to your profile (see Section 2 above and Our Cookie Policy).

We may process Personal Data involving automated decision making, including for the performance of a contract (e.g. avoid fraudulent payment). You can object to the result of the automated decision by sending an email to the contact details in Section 11 below.

  1. 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 or take advantage of personalized features, and the Digital Media services and special services 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 Us 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.

  1. To whom do We disclose your Personal Data 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.

Within the Pernod Ricard Group

We may share your Personal Data for the purposes mentioned in Section 2 and Section 3 within the Pernod Ricard Group, including its affiliates worldwide.

With third parties

We 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 operation of Our Digital Services 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 We do and, where required, are bound by a legal agreement to keep your Personal Data private, secure and to process it only on Our specific instructions;
  • For joint and co-sponsored programs and promotional purposes: When We run a joint or co-sponsored program or promotion on Our Digital Services 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 Us or one of Our affiliates 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 Our safety or rights or those of Our affiliates, customers, or the public;
  • In the event of a merger or acquisition of all or part of Pernod Ricard by another company, or in the event that Pernod Ricard were to sell or dispose of all or a part of the Pernod Ricard business, the acquirer would have access to the information maintained by the Pernod Ricard 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.
  1. Is your Personal Data sent to recipients outside the European Union?

We are a global company, and your Personal Data may be transferred across international borders to countries with a different level of data protection than 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 take 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.

Our main service providers for the operation of Our Digital Media are based in the United States, as are Our partners. Transfers of personal data to these service providers and partners are implemented in accordance with applicable laws and rely on standard contractual clauses as set out by the European Commission. Such service providers and partners, when acting as processors, are also bound by a contract that ensures a high standard of privacy protection and requires (amongst other provisions) that they act only on Our instructions and implement all technical measures necessary on an ongoing basis to keep your Personal Data secure.

  1. 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, or else to 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 Our services or Our Digital Media according to the statute of limitations.

  1. How do We secure your Personal Data?

We take all necessary technical and organizational measures to protect the confidentiality and security of your Personal Data collected via Our Digital Media. These efforts include but are not necessarily limited to: (i) storing your Personal Data in secure operating environments to which the public does not have access, but only Our authorized 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.

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.

  1. 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, although this does not impact the lawfulness of processing based on consent before the withdrawal.
  • 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 if: (i) 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, or (v) the Personal Data must be erased to comply with a legal obligation applicable to Us. We will take reasonable steps to inform Our affiliates of such erasure.
  • You can request the restriction of the processing if (i) the accuracy of your Personal Data is contested, to allow Us 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 for Us 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 We conduct verification to check whether it has legitimate grounds for such processing which may override your own rights, or (v) if the data processing is based on Our legitimate interest.
  • 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, or if the data processing is based on Our legitimate interest (except if We can demonstrate compelling legal grounds for the processing).
  1. How do We treat the Personal Data of minors?

Our Digital Media are not intended for persons under the legal purchase age for alcohol (“Minors”), so We do not knowingly collect personal data from Minors. You must be over the legal purchase age to 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 remove such Personal Data.

  1. How can you contact Us or lodge a complaint with 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:

The Absolut Company AB

Att. TAC Privacy Board

S-117 97 Stockholm

Sweden;

or by sending an email to: privacy@absolut.com.

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 Pernod Ricard. In Sweden, you can contact the Swedish Data protection Authority (Integritetsskyddsmyndigheten) via their website at: imy.se.

  1. Changes to Our Privacy Policy

We keep Our Privacy Policy under regular review and will place any updates on this web page.

This Privacy Policy was last updated in September 2024.

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