Privacy Policy Online Wyborowa Pernod Ricard

Wyborowa Pernod Ricard respects the privacy rights of users when they use digital media (e.g. our websites, phone applications, social media pages, any online forms to register for our events, etc.) and communicate with us electronically.

Therefore, this Privacy Policy aims to inform users how Wyborowa S.A. with its registered office in Poznań at ul. Janikowska 23, 61-070 Poznań and companies belonging to the Pernod Ricard group (collectively referred to as “Wyborowa Pernod Ricard“, “we”, or “our/our/our”) collect, store, use and process Personal Data provided to us via digital media operated by Wyborowa Pernod Ricard (“Media Cyfrowe“).

When processing your Personal Data under the terms of this Privacy Policy, Wyborowa Pernod Ricard acts as the Data Controller for any Personal Data provided to Wyborowa Pernod Ricard.

Przed korzystaniem z naszych Mediów Cyfrowych, należy dokładnie zapoznać się z niniejszą Polityką Prywatności (jak również z Polityką Cookies Wyborowa Pernod Ricard – patrz punkt 2). W przypadku niewyrażenia zgody na Politykę Prywatności lub Politykę Cookies Wyborowa Pernod Ricard, prosimy o niekorzystanie z Mediów Cyfrowych. Zastrzegamy sobie prawo dokonywania zmian postanowień Polityki Prywatności lub Polityki Cookies Wyborowa Pernod Ricard z ważnych przyczyn, tj. w celu dostosowania Polityki Prywatności lub Polityki Cookies do rozwiązań przewidzianych przepisami prawa albo gdy zmiana jest konieczna ze względu na rozstrzygnięcie sądu lub innego uprawnionego organu władzy publicznej albo w celu wdrożenia nowych technicznych sposobów zabezpieczenia prywatności albo gdy jest to konieczne ze względów technicznych związanych ze świadczeniem dla Państwa usług albo gdy konieczność taka wynika ze zmiany zakresu usług oferowanych za pośrednictwem Strony. O wszelkich zmianach będziemy informować użytkowników. Zachęcamy do regularnego czytania Polityki Prywatności i Polityki Cookies Wyborowa Pernod Ricard, aby wiedzieć o wszelkich zmianach w zakresie korzystania z Danych Osobowych użytkowników.

 

1. What Personal Data do we collect and how?

Personal Data” for the purposes of this Privacy Policy means any information that can be used to directly or indirectly identify an individual or contact a user online or offline.

Personal Data is collected only for the purposes set out in point 3 below and with the user’s knowledge (i.e. when knowingly provided in online forms available on our Digital Media) through various contact points, always when participating in the offered functions or services, which may take in particular the form:

  • Registering or subscribing to Digital Media (phone apps, websites, social media, etc.);
  • “Send to a friend” function;
  • lottery and contest;
  • Program or newsletter subscription;
  • Joining the loyalty program;
  • Use related products;
  • Organization of events (invitation or online forms on tablets filled out by our hostesses);
  • Training
  • Brand Home;
  • Reactions, questions, research, polls or comments via the formula
  • Any other requests that require the provision of Personal Data.

The information collected for the above features varies in type and scope depending on the activity. The Personal Data requested includes information that identifies you and certain information about your private life and center of interest (depending on the activities you participate in).

Subject to the requirements of applicable law, we may use various technologies to collect and provide information about access to and use of our Digital Media, as well as demographic data of users of our Digital Media obtained from third parties, e.g. Google or the social media used (“Information about Use“). Such information may include information about the pages visited, duration of visits, access or provision of specific information about drinks or other content, in what language, demographics (e.g. age, gender and fields of interest, where applicable) and pages visited prior to the visit on the current page so that we have more information about the interactions between users and our brands, and then we can adapt and improve them accordingly. Most of the Usage Information collected cannot, in principle, be linked to an individual user, but if it could be linked to a user, it will be treated as the user’s Personal Data in accordance with this Privacy Policy.

 

2. How do we use tracking technologies and why?

Wyborowa Pernod Ricard uses tracking technologies such as cookies, IP address or logs to collect certain data such as browser type and operating system, referrer, user path within the website, Internet Service Provider (ISP) domain name, etc. in order to improve the use of and functionalities of our Digital Media and to better understand how visitors use our Digital Media and the tools and services offered through them. Tracking technologies allow us to tailor our Digital Media to your individual needs.

  • We use Cookies to better understand how users use our Digital Media and the tools and services offered through them and to improve the use and their functionality. Subject to the user’s consent, our Digital Media uses cookies and similar technologies (“cookies”). Cookies are small files placed on the user’s device that serve various purposes, e.g. allow you to navigate between pages efficiently, remember preferences and generally improve the user experience. The use of cookies on our Digital Media allows users to better use the Digital Media and allows for a more accurate assessment of their performance on our Website. More information on the cookies we use and how to block them can be found in the Wyborowa Pernod Ricard Cookie Policy.
  • An IP address is a number that computers on a network use to identify your computer each time you log on to the Internet. We can track IP addresses, e.g. to: (i) resolve technical issues, (ii) maintain the security and protection of the website, (iii) restrict access to our Digital Media to comply with the law or comply with contractual restrictions, and (iv) better understand how users use our Digital Media;
  • We may (or third parties may do so on our behalf) collect data in the form of logs that record activity on our Digital Media and keep statistics on users’ browsing habits on Digital Media. They are generated anonymously and allow us, among other things, to to collect data about: (i) the type of browser and operating system of the user, (ii) the user’s session (e.g. his own URL, date and time of his visit to our Digital Media, and about the pages visited and the duration of these visits) and (iii) other similar surfing data or click-stream data. We also use the information collected in the logs for our internal marketing and demographic research, thus constantly improving and adapting the online services we provide. Logs are for internal purposes only and are not associated with any particular user.

3. For what purpose do we use Personal Data?

All Personal Data collected is used for the purposes for which it was provided to us and/or otherwise specified at the point of collection or in this Privacy Policy.

These purposes include mainly:

1. Response to a user’s request for a service or contract performance

    • When registering or subscribing to our Digital Media to provide a subscribed service: the Personal Data provided are used to offer benefits and privileges usually associated with registration, e.g. , invitation to or participation in an event organized by Wyborowa Pernod Ricard);
    • Reactions, questions or comments via the contact form or compliance notification system (“Tell Us”): when contacted via the online contact form, the Personal Data provided is used to respond to the question or comment.
    • We may use your email address to send you transactional or administrative information (e.g., a confirmation email when you sign up for or cancel a particular registration or activity), as well as certain service-related announcements (e.g., notifications about privacy notice updates suspended features or programs on our Digital Media, changes to our online service or technical support policies or other related changes)

2. Obtaining the possibility of sending marketing content regarding Wyborowa Pernod Ricard or products of this company, subject to the consent of:

    • When using the “Send to a Friend” feature: Personal Data requested for a single-use feature (usually names and email addresses) is used once (e.g. to send a message) and is not stored;
    • When you use a QR Code or similar feature found on Wyborowa Pernod Ricard products: we use Personal Data to send you more information about products that have a QR Code or similar feature or about other products;
    • When consenting to cookies on the terms set out in the Wyborowa Pernod Ricard Cookies Policy;
    • When providing the requested Personal Data on mobile devices, e.g. iPads available at Heritage Centers, distilleries: we use them to send users more information about products;
    • In addition to the purpose for which you have provided your Personal Data, you may also choose (through a checkbox or otherwise) to consent to the use of your Personal Data for activities or services other than the requested activity or primary service. For example, when you enter a contest or other promotion, you may be invited to sign up for newsletters or alerts you receive through the Digital Media running the promotion or other websites. When selecting such additional services, we will use Personal Data to provide them.
    • With your consent, we may from time to time combine, update or otherwise augment Personal Data collected through our Digital Media with data we receive from third party sources or third parties. For example, we may combine purely demographic or survey data (e.g. age, gender, household and other interests, etc.) that is not linked to your Personal Data with Personal Data collected through our offerings (e.g. when registering an account) We may use the above combined personal or demographic data of users for our internal marketing and demographic research and to continuously optimize, personalize and adapt the products and services we offer to the needs of users. Some of the tools we use may include automated individual decision making. In such a case, we inform users about the conditions of profiling and they have the right to use additional safeguards to protect the user’s rights specified in detail in point 9 of this Privacy Policy.

3. Because better service is also in Wyborowa Pernod Ricard’s interest

  • We will keep your Personal Information accurate and up-to-date and avoid duplicating it in our database by checking each time you interact with us or one of our subsidiaries whether your Personal Information is still current or needs to be supplemented or updated using additional information provided to us.
  • After properly informing the user, we may perform profiling based on monitoring the user’s activity on our Digital Media to better understand his preferences or center of interest and adapt our marketing messages to his profile, unless he objects under the conditions set out in point 9 of this Privacy Policy.

 

4. What if you do not agree to provide your Personal Data?

If you choose not to provide Personal Data when asked to do so, you may not be able to participate in certain activities and personalized features, and our Digital Media may limit the services and promotions we offer. For example, if you decline to provide your email address, you will not be able to receive our newsletters or otherwise register with our Digital Media. However, in order to simply browse our Digital Media and find out more about Wyborowa Pernod Ricard and our products, it is not necessary to provide your Personal Data. In any case, we will inform you about the Personal Data that is necessary to use the service.

 

5. Who do we disclose Personal Data to and why?

Wyborowa Pernod Ricard never discloses your Personal Data to third parties who intend to use it for direct marketing purposes, unless we have specifically informed you and you have given your consent.

Wyborowa Pernod Ricard may disclose Personal Data for the purposes indicated in point 3 to related companies (collectively the “Pernod Ricard Group”), in particular in the following circumstances: data collected by us in the manner described in this Privacy Policy may come from the entity to which they are provided but may also be made available, subject to the user’s consent, through such entity to other entities from the Pernod Ricard Group in order to provide the user with news and promotional information about their products or programs that have turned out to be of interest to them.

In order to withdraw consent to the provision and use of such information, such a request should be made in the manner indicated in point 9 of this Privacy Policy, providing your name and surname and withdrawal of consent to providing your Data to all or some entities from the Pernod Ricard Group (providing a list of these entities) and receiving marketing information from them.

Wyborowa Pernod Ricard may also disclose your Personal Data to third parties, but only in the cases indicated below:

  • We may use service providers, agents or contractors to provide support for the internal operation of the Digital Media and to help us manage it or the various features, programs and promotions available. Each third party is obliged at all times to ensure the security of Personal Data at the same level as Wyborowa Pernod Ricard and is obliged to maintain the confidentiality and security of Personal Data and process it only on the specific instructions of Wyborowa Pernod Ricard;
  • 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, we collect and process Personal Data and may disclose it to our partner or sponsor subject to consent where required. If Personal Data is collected (or disclosed) by or to a company other than Wyborowa Pernod Ricard as part of this promotion, we will notify you when collecting Personal Data; When running a promotion with another company, we will provide a separate link to that company’s privacy policy where appropriate, and we encourage you to read that company’s privacy policy before providing your Personal Information, as we cannot guarantee that they follow the same privacy practices. In the event that you do not wish your Personal Information to be collected or disclosed by or to a company other than Wyborowa Pernod Ricard, you may choose not to do so or participate in these events when collecting your Personal Information/when informed of not asked;
  • We may also disclose your Personal Information if we are required to do so by law, or we reasonably believe that doing so is necessary to comply with legal requirements, to respond to claims, or to protect the safety or rights of Wyborowa Pernod Ricard, its customers, or others;
    In the event of a merger or acquisition of Wyborowa Pernod Ricard, in whole or in part, by another company, or in the event that Wyborowa Pernod Ricard sells or disposes of Wyborowa Pernod Ricard, in whole or in part, the purchaser would have access to information held by
  • Wyborowa Pernod Ricard, which could include Personal Data, subject to applicable law. Similarly, Personal Data may be transferred as part of company restructuring, bankruptcy proceedings or in another similar case, if it is provided for by law;
  • We may disclose aggregate Demographic or Survey Personal Data to third parties, but this data is anonymous and does not allow for the re-identification of any individual. The aggregate data we disclose may include anonymous data collected using cookies and other similar tracking technologies as outlined in section 2.

 

6. Is Personal Data transferred to recipients in other countries and why?

Wyborowa Pernod Ricard is part of the global Pernod Ricard Group and your Personal Data may be transferred abroad. They may be transferred to countries with different personal data protection laws than those applicable in the country where the Data was provided. Personal Data may also be transferred between different companies within the Pernod Ricard Group located in different countries. Wyborowa Pernod Ricard applies appropriate measures to ensure the security of Personal Data during their transfer, as well as at the place of their receipt by applying agreements based on standard data protection clauses adopted by the European Commission, in accordance with the requirements of applicable law. The list of countries where Wyborowa Pernod Ricard has an affiliate that may receive your Personal Data is available here.

Our main Digital Media service providers are based in the United States. The transfer of personal data to these service providers is carried out in accordance with applicable law and on the basis of standard data protection clauses adopted by the European Commission or the Privacy Shield package. Such service providers are also bound by an agreement that ensures a high standard of privacy protection and requires, among others, that they act only on the instructions of Wyborowa Pernod Ricard and implement all technical measures necessary to permanently protect Personal Data. The User has the right to obtain detailed information on the mechanism according to which the data is transferred outside the EEA by writing to the address: regulation@wyborowa.com

 

7. How long do we store Personal Data?

The Personal Data provided to us via Digital Media is stored in our databases for the time that the user account remains active, as long as required by the contract concluded with the user or for the time needed to provide the requested services or answer questions or send solutions to problems, provide improved and new services. We may also store your Personal Data for a longer period in accordance with our internal procedure in this regard, if it is necessary to comply with obligations arising from generally applicable laws, to resolve disputes and to enforce contracts.

We may therefore store Personal Data after you have finished using Wyborowa Pernod Ricard services or our Digital Media. The other recipients of your Personal Data identified in Section 5 may retain your Personal Data for a longer period where this is necessary to fulfill the purpose for which we obtained your consent to disclose the Personal Data to them, or for their own compliance, dispute resolution, enforcement or management of archives in accordance with applicable law.

The storage periods for cookies and other tracking programs are detailed in the Wyborowa Pernod Ricard Cookies Policy

8. How do we secure your Personal Data?

Wyborowa Pernod Ricard applies all necessary technical and organizational measures to ensure confidentiality and protection of Users’ Personal Data collected via this website or our applications (Digital Media), including Sensitive Data. These activities include, but are not limited to: (i) storing Personal Data in secure operating conditions that are not publicly available and that are only available to authorized Wyborowa Pernod Ricard employees, agents and contractors; and (ii) verifying the identity of registered users before granting them access to stored Personal Data.

 

9. How to exercise the rights to use your Personal Data?

In order to exercise your rights related to the processing of your Personal Data, please contact us at the address indicated in point 12 below:

  • If the Personal Data were processed on the basis of the user’s consent, the user may withdraw the consent at any time, the withdrawal of consent does not affect the lawfulness of the processing of personal data before the consent was withdrawn
  • The User may request access to the content of their Personal Data, in particular the categories of data used for profiling or decision-making
  • The User may request the correction of their Personal Data if they are inaccurate, incomplete or outdated, in particular data in the profile
  • The User may request the deletion of their Personal Data (i) when they are no longer necessary for their processing, (ii) withdraw their consent to data processing only within the scope of this consent, (iii) object to data processing, (iv) unlawful processing of Personal Data, (v) when the Personal Data needs to be deleted in order to comply with a legal obligation applicable to Wyborowa Pernod Ricard. Wyborowa Pernod Ricard will take reasonable steps to inform other entities of the Wyborowa Pernod Ricard Group.
  • You may request restriction of processing (i) where you contest the accuracy of your Personal Data to allow Wyborowa Pernod Ricard to verify the accuracy, (ii) where you wish to restrict the processing of your Personal Data rather than delete it although the processing is incompatible with by law, (iii) if you want Wyborowa Pernod Ricard to store your Personal Data because they are necessary to defend against claims, (iv) if you have objected to the processing but Wyborowa Pernod Ricard carries out verification to verify grounds for such processing that may override your rights.
  • The user may request the transfer of the provided Personal Data in cases provided for by law, in particular when the processing is carried out on the basis of the user’s consent or in order to perform the contract.
  • You always have the option to refuse to provide us with your Personal Data. In this case, the activities and functions offered will be limited.
  • The User has the right to object to the processing of their Personal Data by us, in particular processing for marketing purposes based on profiling.

If you do not wish to receive newsletters, announcements or other messages or services via Digital Media, please do not select the option to receive such messages or services when registering. If you choose this option and later opt out, please click on the unsubscribe link in our communications.

For each email, we give users the option to opt out of receiving them in the future (i.e. unsubscribe). Just complete the cancellation process or follow the instructions in the email.

The User also has the right to give general or specific instructions on the use of personal data processed on the basis of this Privacy Policy after his/her death.

In addition, if you participate in a program in which third parties are involved and express, under this program, consent to receive messages directly from these third parties in the future, you should contact these entities directly to unsubscribe from receiving them. This process may be described in the privacy policies of these third parties.

In the event of exercising your rights, you may be asked to provide proof of identity.

Wyborowa Pernod Ricard will not process Personal Data involving automated decision-making, unless it is necessary for the performance of a contract (e.g. to avoid fraudulent payment) or subject to the user’s explicit consent, in order to better meet the user’s needs in accordance with his preferences. It should be noted that in this case, we will provide you with information via layered notices about the conditions of processing your Personal Data, the created profile, how to use the profile and the rationale for this process. We will also ask for your express consent to such profiling, if it is not necessary for the performance of the contract.

Please note that automated tools are regularly reviewed to ensure the fairness of the processing of Personal Data. When creating profiles, specific measures are implemented, e.g. regarding data minimization. We are happy to hear your opinion expressed through the above right of access. The User may also object to the result of an automated decision by sending an e-mail to the contact address indicated in point 12 below.

 

10. How do we treat minors’ Personal Data?

Our Website is not intended for minors (“Minors“), so we do not knowingly collect their personal data. You must be at least eighteen years of age to set up an account and take action on our Digital Media. Setting up an account or taking action on our Digital Media means that the person doing so has declared that he or she is at least eighteen years of age and capable of committing to our Terms and Conditions and this Privacy Policy. In the event of notification that the Personal Data provided via Digital Media was provided by a Minor, the Data will be deleted.

 

11. Links to other third party websites

Our Digital Media may contain links to other websites or services operated or controlled by third parties. These are links from advertisers, sponsors and partners using our logo(s) as part of a co-branding agreement. These entities are independent of us, therefore the use of their websites and functions is subject to the privacy policies of these entities placed on these websites. We are not responsible for or responsible for the privacy practices or business practices of any third-party sites. Therefore, before providing your Personal Data, you should exercise caution and familiarize yourself with the relevant privacy policies applicable to the third-party sites you visit.

 

12. Contacting the company or the relevant Control Authority

If you have any questions, complaints or comments regarding this Privacy Policy or our data collection practices, please contact Wyborowa Pernod Ricard by sending an email to: regulations@wyborowa.com.

Please be advised that in case of doubts regarding the conditions of processing your Personal Data by Wyborowa Pernod Ricard, you can also lodge a complaint with the supervisory authority (the Inspector General for Personal Data Protection or the President of the Office for Personal Data Protection: the name of the authority will depend on the legal status at the time of lodging the complaint).

Ostatnia aktualizacja: MAJ 2018