Privacy Policy
We take your privacy very seriously and we respect 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 and whenever else you communicate electronically with us (“Digital Media”).
Please read this Privacy Policy carefully as it contains important information on who we are and how and why we collect, store, use and share your Personal Data. It also explains your rights in relation to your Personal Data and how to contact us or supervisory authorities in the event you have a complaint.
"We", "us" and "our" refer to Pernod Ricard Hong Kong and Macau, a division of Pernod Ricard Asia Duty Free Limited, a corporation duly organized under the laws of Hong Kong, with its registered address at 25/F, Tower 5, The Gateway, 15 Canton Road, Harbour City, Tsimshatsui, Kowloon, Hong Kong (all together "Pernod Ricard”, “we”, “us” or “our”). We are the data controller when processing your Personal Data in the conditions described in this Privacy Policy, which includes any Personal Data you submit to this website or another website that links you to this Privacy Policy, such as a microsite that we use to run a promotion or competition (the "Website").
Topics
What Personal Data do we gather about you?
For what purpose do we use your Personal Data?
How do we use your Personal Data for direct marketing?
How is your Personal Data collected?
How and why do we use tracking technologies?
What happens if you do not wish to provide your Personal Data?
To whom do we disclose Your Personal Data and why?
Is your Personal Data sent to recipients located in other countries and why?
How long do we keep your Personal Data?
How do we secure your Personal Data?
What are your rights regarding Personal Data?
How do we process children’s Personal Data?
Do we link to other third-party websites?
How can you contact us?
Changes to our Privacy Policy
- What Personal Data do we gather about you?
Personal Data means any information that can be used to personally identify you or contact you online or elsewhere, which may be collected when you use our Digital Media.
We may collect and use the following Personal Data about you:
your name and contact information, including postal address, email address and telephone numbers and, if applicable, company details
information to enable us to check and verify your identity, e.g. your date of birth
your gender information, if you choose to give this to us
location data
your billing information, transaction and payment card information
information to enable us to undertake credit or other financial checks on you to the extent permitted by applicable law
your personal or professional interests, household, lifestyle, habits and preferences
your professional online presence, e.g. LinkedIn profile
your contact history, purchase history and saved items
information from accounts you link to us, e.g. Facebook
information about how you use our Website, IT, communication and other systems
your responses to surveys, competitions and promotions
your IP address and your mobile/tablet/device ID
Personal Data is collected only for the purposes set out in Section 2 and 3 below and each time you participate in any of the features or services offered by our Digital Media. This Personal Data is required to provide products and Digital Media to you. If you do not provide Personal Data we ask for, it may delay or prevent us from providing products or services to you.
- For what purpose do we use your Personal Data?
We collect information about you to:
- Respond to your request of service based on the performance of our contract with you
- When you register or sign-up in our Digital Media (mobile app, Websites, social media, etc.), 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. receiving the communications you select at the time of registration, being invited to events, participating in a sweepstake, etc.);
- When you purchase products on our Websites: we use your Personal Data to manage your order and deliver your products.
- 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 Services, changes to our online services or technical support policies, or other related changes)
- Allow us to send you promotional or marketing information, as described in Section 3 below, when you consent.
Allow us to learn more about your tastes and preferences through agreed interactions with you and more generally log our interactions with you to learn more about your tastes, your expectations, understanding how you use our services to provide a more customized service and improve our offers to you. This would also allow us to send you marketing communications better tailored to your interests and thus more relevant. In addition, we may also provide you with marketing information by displaying advertisements on Pernod Ricard Digital Media and/or any digital advertising platforms such as social media platforms) about the various brands we sell.
- To provide the best service to you:
- Subject to your consent when required, 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 any Personal Data about you with Personal Data collected through our offers (such as during account registration).
- We may use the combined above-mentioned 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. Some of the tools we use may involve automated individual decision-making subject to applicable law.
- Respond to your 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 Personal Data is used to respond to your inquiry or comment.
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 will have provided.
- We may conduct profiling based on monitoring your browsing activities on our Digital Media to better understand your preferences and center of interests and adapt our marketing communications to your profile, unless you object in the conditions set forth in Section 11 of this Privacy Policy.
Manage your requests to exercise your rights, as described in Section 11 below, based on our legal obligations.
Respond to requests from the relevant authorities and defend our rights based on our legal obligations. If we receive a subpoena or another legal request, we may need to inspect the data we hold to determine how to respond.
Pernod Ricard may process Personal Data involving automated decision making, including 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 the automated tools used are regularly checked to ensure that the Personal Data is processed fairly. Specific measures such as data minimization are implemented when creating profiles. For any claim regarding the result of the automated decision, you can contact us by email to the contact details in Section 14 below.
- How do we use your Personal Data for direct marketing?
Subject to your consent (which includes an indication of no objection), we may use and share your name, contact details, profile information (including place of residence, location based on IP address and transaction data) with other entities (see Section 7 for details) for direct marketing purposes. Specifically:
- We may provide you with marketing information by electronic communications, such as newsletters, phone calls, or equivalent feature displayed on our products. Additionally, we may display advertisements tailored to you and individuals with similar profiles on Digital Media and/or any digital advertising platforms, including social media platforms about the various brands we sell.
- In addition to the purpose for which you submitted your Personal Data, you may also be given the option (through a check box or otherwise) to have your Personal Data used for an activity or service different from the primary activity or service that you are requesting. For example, if you are signing up for a contest or other promotion, you may also be invited to sign up for newsletters or alerts from our Digital Media hosting the promotion or from other websites. If you choose to receive these additional services, we will use your Personal Data to provide them to you.
- When you use the “Send to a friend” feature: this Personal Data is used only once to send the communication and is not further retained by us, as appropriate according to local law.
- When you use a QR Code or equivalent feature displayed on Pernod Ricard products: we use your Personal Data to send you more information on the products where the QR code or equivalent feature is displayed or other products.
From time to time, you may decide to “opt in” to, or to “opt out” from, use by us of your Personal Data for promotional and marketing purposes. Every time you receive marketing information from us, you will be given the option to opt out by following the instructions provided therein. You can also contact us at any time to cease the use and sharing of your personal information for direct marketing purposes by email to the contact details provided in Section 14 below.
How is your Personal Data collected?
Personal Data we collect from you:
We collect most of this Personal Data directly from you—in person, by telephone, text or email and/or via our Website and apps. This usually occurs when you take part in one of our promotional activities or subscribe to one of our Digital Media, for example:
- Registration or sign-up online: e.g. mobile app, Websites, social media or subscribing to a newsletter specific to our Digital Media or creating an account to be a member of a club;
- 'Send to a friend' marketing communications;
- Sweepstake, lucky draws and contest;
- Joining a loyalty program or subscribing to a newsletter;
- Buying products or services online;
- When doing e-commerce on certain of our Websites;
- Using a QR Code displayed on products;
- Events (invitation form or online forms on tablets filled out by our representatives with your input);
- Attending any of our experience courses or events;
- Brand Websites;
- Training;
- Tastings;
- Feedback, questions, enquiries, surveys or comments through 'Contact us';
- Any other request that requires the submission of Personal Data.
The types and amount of information collected for the above-mentioned features and services may be updated and vary depending on the activities of Pernod Ricard.
Personal Data we collect from other sources:
We may also collect information:
from publicly accessible sources, to the extent permitted by applicable law;
directly from a third party, e.g.: "Send to a friend" marketing communications or a third party sign-up form from one of our partners;
from credit reference agencies to the extent permitted by applicable law;
from customer due diligence providers;
from a third party that you use;
from cookies on our Website
via our IT and other systems, e.g.: automated monitoring of our Website and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.;
We may also receive information if you have provided permission to other organisations to share it with us. Before providing permission to such third party organisations to share your personal information, you should check their privacy notices carefully. Subject to applicable law requirements, we may use a variety of technologies that collect and provide information about how our Digital Media is accessed and used by you. We may also use demographic information about who uses our Digital Media, which we get from third parties such as Google or social media that you use (we call this “Usage Information”).
Usage Information may consist of the pages you visited, the time you visited them and which beverage information (or other content) you accessed or provided. It also includes which language you use, demographic information about you (such as your age, gender and interest areas, where available) and which pages you have visited before visited the current page.
- How and why do we use tracking technologies?
Pernod Ricard uses tracking technologies such as cookies, IP Address recording or Log files, to gather technical information such as your web browser type and which operating system you use, the webpage you came from, your path through our Website and your Internet Service Provider. This is so we can improve the functionality of our Websites and better understand how visitors like you use our Digital Media and the tools they offer.
Often, individuals will interact with us in multiple ways and will provide us with personal information in different contexts. We may use your personal information to obtain a profile of your different interactions with us and to understand your preferences.
These tracking technologies help us tailor our Digital Media to your personal needs:
- Subject to your consent where required by applicable law, our Digital Media use cookies and similar technologies (“cookies”). Cookies are small files placed on your device which serve a number of purposes, such as remembering your preferences. Cookies let you enjoy a richer and more tailored browsing experience, as well as help to accurately measure your behaviour on our Website.
- An IP address is a number on a network to identify your computer every time you connect to the Internet. We may keep track of Internet Protocol (IP) addresses to (among other things): (i) troubleshoot technical concerns, (ii) maintain Website safety and security, (iii) restrict access to our Digital Media to certain users, (iv) track location and behaviour, analyse, segment and target advertising to customers, and, (iv) better understand how our Digital Media is utilised e.g. using Google Analytics ;
We (or a third party on our behalf) may collect and use your mobile/tablet device ID to provide a more tailored browsing experience, to alert you to nearby events or promotions and for reporting and analysis;
- We (or a third party on our behalf) may collect information in the form of logs files that record activity and gather statistics about browsing habits. These entries are generated anonymously, and help us gather (among other things) (i) your browser type and operating system, (ii) information about your session (such as the URL you came from, the date and time you visited our Digital Media, and which pages you have viewed and for how long), and, (iii) other similar navigational or click-stream data. We also use log-file information for our internal marketing and demographic studies, so we can constantly improve and customize the online services we offer you. Log files are only used internally, and are not associated with any personally identifiable individual.
- What happens if you do not wish to provide your Personal Data?
- To whom do we disclose your Personal Data and why?
If you choose not to submit Personal Data as described in this Privacy Policy when requested notably through collection forms or when interacting with you, you may not be able to participate in certain activities or use some of the personalized features of our Digital Services, This may also 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 any of our newsletters or otherwise register on our Digital Services. However, you do not need to give us any Personal Data to simply browse our websites and learn more about us and our products.
- Within the Pernod Ricard Group
- With third parties
Pernod Ricard may share for the purposes mentioned in Section 2 and 3your Personal Data within the Pernod Ricard Group, including its affiliates worldwide. Your personal data can be processed by our Pernod Ricard Brand Compagnies. In such case those Pernod Ricard entities provide support services as processor of Pernod Ricard Hong Kong.
Pernod Ricard may also share your Personal Data with third parties, but only in the following circumstances:
- Service providers assisting us for marketing purposes.
- For support purposes: We may use service providers, agents or contractors to provide support for the internal operations of our Digital Media 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 Pernod Ricard and, where required, are bound by a legal agreement to keep your Personal Data private, secure and to process it only on the specific instructions of Pernod Ricard;
- For joint and co-sponsored programs and promotional purposes: 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 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 Pernod Ricard 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 the safety or rights of Pernod Ricard, its 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 that 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
- Is your Personal Data sent to recipients located in other countries and why?
- How long do we keep your Personal Data?
- How do we secure your Personal Data?
- What are your rights regarding your Personal Data?
Pernod Ricard 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. Pernod Ricard 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, supplemented as necessary by additional measures in accordance with applicable Data Protection Law.
Our main service providers for the operation of our Digital Media are based in the United States. The transfer of personal data to these service providers are implemented in accordance with applicable laws and rely on standard contractual clauses as set out by the European Commission or on the EU-US Data Privacy Framework, when relevant. 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 Pernod Ricard instructions and implements all technical measures necessary on an ongoing basis to keep your Personal Data secure.
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, provide improved and new services. We may also retain your Personal Data for the applicable statute of limitation, 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 have to retain your Personal Data after you stop using Pernod Ricard services or our Digital Media according to comply with such obligations.
Pernod Ricard 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 Pernod Ricard 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.
You have the following rights, which you can exercise free of charge:
- Access. You can ask us to confirm whether we are processing your Personal Data and, if so, to provide you with a copy and inform you of the characteristics of the processing.
Rectification. You can ask us to rectify or complete inaccurate or incomplete Personal Data.
Deletion. You may ask us to delete your Personal Data in specific cases (e.g., if it is no longer required for the purposes for which it was collected, if you have withdrawn your consent).
Restriction. You may ask us to restrict the processing of your Personal Data in specific cases (e.g., if you contest the accuracy of your Personal Data).
Portability. You can ask us to provide you with your Personal Data in a structured, commonly used and machine-readable format, or you can request that it be transferred directly to another data controller, but only where the processing is based on your consent or on the performance of a contract and the processing is carried out using automated processes.
Right to object to marketing. You may object at any time to your Personal Data being processed for direct marketing including profiling.
Withdrawal of consent. You may withdraw your consent at any time to any processing of Personal Data based on your consent, where applicable, without compromising the lawfulness of the processing based on consent carried out prior to such withdrawal.
If you would like to exercise your right to object to direct marketing or any of your other rights, please contact us at any time by email to the contact details provided in Section 14 below.
Your objection (or withdrawal of consent) may mean we cannot provide the products or services you have requested of us or you may not be able to use the services we offer. We will advise you where this is the case. In certain circumstances even if you withdraw your consent we may still be able to process your Personal Data if required or permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and regulatory obligations.
If you participated in a program that involved a third party and you agreed to receive communications from that third party, you will need to contact them directly to opt-out. This process should be outlined in the third party's privacy policy.
- How we treat children's Personal Data?
- Do we link to other third-party websites?
- How can you contact us?
- Changes to our Privacy Policy
Our Digital Media are not intended for children under the legal drinking age (“Minor”), so we do not knowingly collect personal data from Minors. You must be or declare to be at least eighteen years old to register or create an account and 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 delete such Personal Data. If you wrongly declare you are at least 18 years old, Pernod Ricard cannot be liable for any consequences of your misdeclaration.
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 brands or logo(s) as part of a co-branding agreement.
The operators of other sites may collect information from you which will be used by them in accordance with their own data protection policy or privacy policy. We have no control over these third parties, and your use of their websites and features are subject to the privacy policies posted on those websites. 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 those external websites you visit, before you provide your Personal Data.
If you have any questions, complaints, or comments regarding this Privacy Policy or our information collection practices, please contact us by writing to:
Pernod Ricard Hong Kong and Macau
A division of Pernod Ricard Asia Duty Free Limited
25/F, Tower 5, The Gateway,
15 Canton Road, Harbour City,
Tsimshatsui, Kowloon,
Hong Kong.
or sending an email to: hkdpo@pernod-ricard.com
You can also exercise your rights in this Privacy Policy, such as making an access, rectification or deletion request by sending an email to us at hkdpo@pernod-ricard.com.
We keep our Privacy Policy under regular review and we will place any updates on this web page. If we make material changes to how we collect, use, or share your personal information, we will notify you via email (sent to the last email address you provided) and/or by posting notice on our website at www.le-cercle.hk. These changes will be effective 30 days after we send the email or post the notice. Material changes may impact how we handle personal information collected before the notification. If you disagree with these changes, you must notify us in writing before the effective date, as described in Section 14.
This Privacy Policy was last updated in December 2024.
