"We", "us" and "our" refer to Le Cercle and Pernod Ricard Singapore Pte Ltd.
We collect, use and are responsible for certain Personal Data about you. When we do so we are subject to Singapore’s Personal Data Protection Act.
1. What Personal Data do we collect about you and how?
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 Services.
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
- 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
This Personal Data is required to provide products and Digital Services 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.
2. How your Personal Data is 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 Services, for example:
- Registration or sign-up online: e.g. mobile app, websites, social media or subscribing to a newsletter specific to our Digital Services 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;
- Feedback, questions, enquiries, surveys or comments through 'Contact us';
- Any other request that requires the submission of Personal Data.
The type and amount of information we collect for the features listed above will vary and depends on the activity.
Personal Data we collect from other sources:
We may also collect information:
- from publicly accessible sources;
- 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;
- 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 websites 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 laws, we may use a variety of technologies that collect and provide information about how our Digital Services are accessed and used by you. We may also use demographic information about who uses our Digital Services, 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 have 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 you visited the current page.
How and why do we use tracking technologies?
We use 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 Services 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 Services to your personal needs:
- An IP address is a number used 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 issues, (ii) maintain website safety and security, (iii) restrict access to our Digital Services to certain users, (iv) track location and behaviour, analyse, segment and target advertising to customers, and, (iv) better understand how our Digital Services are 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 web 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 Services, 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 customise the online services we offer you. Log files are only used internally, and are not associated with any personally identifiable individual.
3. For what purpose do we use your Personal Data?
- Respond to your request of service or for the performance of a contract
- 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 Media, changes to our online services or technical support policies, or other related changes)
- Allow us to send you marketing information when you consent:
- 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;
- Because it is also Pernod Ricard legitimate interest to better serve 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.
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.
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. You are invited to express your point of view through the right of access described above. You can also object the result of the automated decision by sending an email to the contact details in Section 11 below.
4. What happens if you do not wish to share your Personal Data with us?
If you choose not to submit any Personal Data when requested, you may not be able to participate in certain activities or use some of the personalised 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 for 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.
5. Who do we disclose your Personal Data to and why?
- Within the Pernod Ricard Group
Pernod Ricard may share for the purposes mentioned in Section 3 your Personal Data within the Pernod Ricard Group, including its affiliates worldwide.
- With third parties
Pernod Ricard 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 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
6. Is your Personal Data sent to recipients located in other countries and why?
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, in accordance with applicable 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 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 Pernod Ricard instructions and implements all technical measures necessary on an ongoing basis to keep your Personal Data secure.
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, 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 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 Pernod Ricard services or our Digital Media according to the statute of limitations.
8. How do we keep your Personal Data secure?
We have appropriate security measures to prevent your Personal Data from being accidentally lost, or used or accessed unlawfully. These include: (i) storing your Personal Data in secure operating environments that are not available to the public and that are only accessible to authorised employees, our agents and contractors; and, (ii) verifying the identities of registered users before they can access Personal Data we store 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.
9. Your rights
You have the following rights, which you can exercise free of charge:
You can ask us to:
- provide a copy of your personal data (the right of access)
- correct any mistakes in your personal data
- delete your personal data—in certain situations
- restrict processing of your personal data—in certain circumstances, e.g. if you contest the accuracy of the data
- provide you with a copy of the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
You can object:
- at any time to your personal data being processed for direct marketing including profiling;
- in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests
If your Personal Data has been processed on the basis of your consent, you can withdraw your consent at any time. We hope that we can resolve any query or concern you may raise about our use of your information. You also have the right to complain to the Singapore Personal Data Protection Commission.
If you would like to exercise your right to object to direct marketing or any of your other rights, please email our Data Protection Officer at email@example.com
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.
10. How do we treat children's information?
11. Do we link to other third party websites?
Our Digital Services 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.
12. How can you contact us?