Personal Information Protection Policy

Updated and released on: March, 2022

Effective date: March, 2022

Note: This Personal Information Protection Policy becomes effective on the date of renewal. You agree to apply the updated Personal Information Protection Policy from March 2022.You can click to view the old version of the Privacy Statement。


Preface:

Pernod Ricard China respects each customer's right to privacy and takes the protection of each customer's personal information very seriously. To this end, we inform you by this Personal Information Protection Policy (this "Policy"”) about how we collect, use, store, share, transfer, and publicly disclose your relevant information when you visit or use the websites ("Pernod Ricard Websites") or mobile applications (including but not limited to "Pernod Ricard Loyalty Program", "Pernod Ricard Le Code+", hereinafter collectively referred to as "Pernod Ricard Mini Programs") operated and managed by us in the mainland of China or use our products or services or participate in our events through third-party applications or entries ("Open Platforms", together with the Pernod Ricard Websites and the Pernod Ricard Mini Programs, hereinafter collectively referred to as "Network Platforms"). Therefore, please be sure to read this Policy carefully and make a choice you deem appropriate.


The entities of Pernod Ricard China that may process your personal information in accordance with this Policy are:

  • Pernod Ricard (China) Trading Co., Ltd., located on the 6th floor, No. 15 (Building C), Lane 458, Madang Road, Huangpu District, Shanghai, mainly engaging in product sales, distribution, and related sales, marketing, and activities.

  • Pernod Ricard (China) Spirits & Wines Co., Ltd., located at Room 1115, 11th Floor, No. 6, Jilong Road, China (Shanghai) Pilot Free Trade Zone, mainly engaging in certain sales, marketing, and activities.

  • Conviviality (Shanghai) Food Sale Co., Ltd., located at Unit 01a-1 and Unit 01d, Building 16, Lane 181, Taicang Road, Huangpu District, Shanghai, mainly engaging in online and offline retail of goods and related sales, marketing, and activities.

In this policy, the above Pernod Ricard China entities are referred to as "Pernod Ricard", "our" or "us". An entity of Pernod Ricard China determined at the time of cooperation between you and Pernod Ricard will be responsible for specific matters concerning such cooperation.


Please note that we may integrate the personal information collected from different sources (such as the Pernod Ricard Websites, the Pernod Ricard Mini Programs, the Open Platforms, and off-line events). To this end, we will integrate the personal information collected by different entities or cooperative partners of Pernod Ricard. If you want to know how to refuse such treatment, please refer to Section 4 below for more information.


Our Network Platforms is only accessible to the users at or above the legal buying or drinking age. If you have not reached the legal buying or drinking age of the place of your residence or the place where you surf the Internet (in China, the legal buying or drinking age is 18) , please do not provide us your personal information. We never intend to collect any personal information of people below the legal buying or drinking age, nor do we intend to promote our products to such group. Users under the legal buying or drinking age are prohibited from using our Network Platforms and related services provided by our Network Platforms. In order to ensure that we provide related services for the users at or above the legal buying or drinking age only, we may collect your date of birth anonymously. Such information will be used only for verifying whether or not you have reached the legal buying or drinking age.


In addition, we may make separate personal information protection policy with respect to certain specific products, services, or scenarios and explain to you the special policy that applies to such products, services, or scenarios. When there is any discrepancy between relevant personal information protection policy and this Policy, such special personal information protection policy shall prevail.


If you have any questions about this Policy or any matters concerning this Policy, you may contact us by the feedback channels listed in the section "Contact us" and we will give you answers as soon as possible.


The section headings of this Policy are as follows:

1. How we collect or use your personal information

2. How we share, transfer, publicly disclose, or entrust others to process your personal information

3. How we store your personal information

4. Your personal information rights

5. How we use Cookies and similar technologies

6. Cross-border transmission of personal information

7. External provision and link to other websites

8. How we protect your personal information

9. Updates and scope of application of this Policy and governing law

10. Contact us and dispute resolution


1. How we collect or use your personal information

Personal information refers to any information that may be recorded electronically or in any other form and is related to an identified or identifiable natural person. We will collect and use, on the principles of legality, legitimacy, and necessity, for the purposes stated below the personal information that may be provided by you on your own initiative in the process of using services or may be generated for your use of our services. To use your personal information for any purpose not stated herein or in any scenario not stated herein or use any information, that has been collected for a particular purpose, for any purpose other than such particular purpose, we will inform you reasonably and obtain your consent anew.


Please note that any information is not personal information if it, singly or in combination with other information, cannot be used to identify you or directly establish relationship with you. Moreover, anonymized information (the personal information that has been processed by technological means so that its subject cannot be identified and cannot be restored upon processing) is not personal information. We do not need to obtain your authorization or consent to collect or use such type of information. If your information is used to identify you singly or in combination with other information, we will process and protect such information as your personal information in accordance with this Policy


1.1The circumstances under which you must authorize us to collect and use your personal information

We will collect, store and use the following information relating to you on the principles of legality, legitimacy, and necessity to realize the following features. If you do not provide such information, you will be unable to enjoy relevant products or services to be provided by us. Such features include:


(1) To verify whether you have reached the legal buying or drinking age

When you are on our Network Platforms, we may collect the date of birth from you to verify whether you have reached the legal buying or drinking age of the place of your residence or the place where you surf the Internet. According to our requirements and rules of lawful operations, we shall not sell liquor or promote liquor products to minors.


(2) To help you join the Pernod Ricard Loyalty Program

Some of our commodities, benefits, and special rights and interests, including member special offers/lucky draw/invitation to events of the same kind/notification of initial launch of new channel products/loving care for member registration anniversary /member point alert/marketing information push etc. (hereinafter collectively referred to "Member Services") , are provided for the members of Pernod Ricard only. You may register as a member on the page of member registration invitation or on any other platform such as the Pernod Ricard Loyalty Program and you may inquire about various member information in real time on the member platform upon completion of registration. To create your Pernod Ricard member account, you shall provide us with your mobile phone number at the least. We may verify your identity by sending SMS verification code. If you need to use browsing or search service only, you are not required to register as member or provide the aforementioned information.

You may modify or supplement your member nickname, gender, and date of birth (subject to the page of "Personal Data") on the member information page. Such information may help us provide you with better service experience. You may refuse to provide such information without affecting your use of the basic service features of the Network Platforms. (The aforementioned information constitutes your member information.We will use the member information for the Member Services.)


(3) To display the information on commodities and services to you

The visitor mode is available on the Pernod Ricard Websites and the Pernod Ricard Mini Programs and browsing and information search may be carried out without logging in or registering as member. However, you need to register and log in to an account to place, view, or manage orders or use other features of the Pernod Ricard Websites or the Pernod Ricard Mini Programs.


If you authorize the registration or login on the Pernod Ricard Mini Programs by any third-party platform account, we will obtain your third-party platform account information, including the mobile phone number provided by you to such third-party platform, your unique user identifier, nickname, and profile photo, as well as other information displayed on such third-party platform, from such third-party platform upon your authorization or with your consent and bind such information to the Pernod Ricard account to identify you and facilitate your registration or login. We will use your personal information aforementioned after ascertaining the legality of source of the personal information according to the agreement with the third party concerned on the premise that such use is in line with applicable laws and regulations (all aforementioned information constitutes your account information).


After you have registered the account successfully, we will communicate, about such matters as invitation to events of the same kind/ marketing information push/notification of initial launch of new channel products, with the user using the account information.


(4) Information on orders and events concerning commodity purchase and application for giveaways

To purchase commodities or apply for giveaways or exchange or consume points, cards, coupons, products, or services of us on-line, you need to provide yourconsignee name, delivery address, and contact numberat the least. When an order is created, the order number, the item or service being ordered or exchanged, the time of order creation, the amount payable by you, and the means of payment will be stated in the order.


To order the aforementioned commodity or service for any third party, you need to provide such third party's consignee name, delivery address, and contact number. When providing us with the aforementioned information about such third party, you shall ensure that you have been authorized duly by such third party and such third party has been informed of and accepts our Personal Information Protection Policy.

(All the aforementioned information constitutes your order information.We will use the order information to verify identity, confirm transactions, settle payments, deliver goods, inquire about orders for you, and provide customer service inquiries and after-sales services. In addition, we will use the order information to judge whether your transactions are abnormal or not so as to protect the security of your transactions. If you do not provide such information, you will be unable to use our services.)


In certain specific scenario (such as the WeChat applet "Pernod Ricard Le Code+") , we may offer benefits such as exclusive discount coupons for the members of Pernod Ricard or carry out marketing events on the third-party platform which is bound to any of the Pernod Ricard Mini Programs. Therefore, if you are a user of such third-party platform, you may receive relevant member benefits or participate in the marketing events only after you have registered your Pernod Ricard member account through such third-party platform or bind your account on such third-party platform to your Pernod Ricard member account. To this end, for the purposes of safeguarding your lawful rights and interests and preventing fraud, you need to agree that we may, and authorize us to, obtain from such third-party platform and transmit your unique user identifier on such third-party platform and the information on the receipt and write-off of the member benefits when you receive the member benefits or participate in the marketing events.


(5) Payment, recharging, and invoicing

When paying, you may make payment by the payment services provided by any of the third-party payment agencies (including such payment channels as Alipay and WeChat Pay，hereinafter collectively referred to as "Payment Agency") in cooperation with us. To realize payment, we will share your order number and transaction amount with such payment agency, give the payment instruction, and help you complete the payment. If your do not provide the aforementioned information, you may be unable to use relevant payment service.


If you apply for the issuance of an invoice by us, we need to collect from you and use your order number, order time, invoice amount, name, and E-mail address at the least, subject to the information displayed on the invoice application page.


(6) Delivery of products or services

After you place an order, the third-party partners (including third-party delivery companies) in cooperation with us will implement the reception, transmission, and delivery of the order. To ensure normal delivery of your order, you shall understand and agree that our third-party partners may use your order informationfor the purposes stated in the present Section.


(7) Customer services and after-sales services

To contact you, help you solve any problem, or record the solution and result of relevant problem, our customer service staff may use your member information and order information as well as other information that may be disclosed by you in the process of contacting the customer service staff. In addition, in order to protect the security of your account, our customer service staff may use your member information, order information, name, contact telephone number, and address address to verify your identity. Moreover, when you communicate with our customer service staff, we may, depending on the circumstance, require you to provide other reasonable and necessary information in addition to the above-mentioned information to further respond to your needs, check your identity, or handle your complaint.


(8) Message notification services

You may receive relevant information, such as the information relating to your orders, marketing information, and consumer comments, by our message notification services (including App push and short message) provided by us. To provide such services for you, we may need to share your device information and location information with our designated message sending or pushing service suppliers under your authorization. Device information refers to any information about the device that may be used by you in the process of access or use and received and recorded by us according to your specific operations in such access or use, including your software and hardware feature information, such as device model, operating system version, device settings, device identifiers such as MAC address, IMEI, IMSI, Android ID, IDFA, and OAID, device environment, and list of mobile applications.


Please note that single device information and service log information cannot be used to identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person or otherwise use such non-personal information in combination with any personal information, such non-personal information will be deemed as personal information during the period of combined use, and will be processed and protected as your personal information in accordance with this Policy.


We will prudently evaluate the legality, legitimacy, and necessity of collection of the aforementioned information by the suppliers and require such suppliers to take strict measures to protect your information and abide by applicable laws, regulations, and regulatory requirements.


(9) Commenting and sharing features

You may release information by the commenting feature provided by us, but it should be noted that the information released publicly by you, such as the image or video containing personal information that may be uploaded by you in the process of commenting, may involve your or others' personal information and even sensitive personal information . You should more prudently consider whether to share and even publicly share relevant information when using our services.


If the information released publicly by you involves any other person's personal information, you shall obtain the consent of such person prior to release.


(10) Marketing and promotion events

We may use your account information and member information to send promotion messages or commercial advertisements to you. If you do not want to receive such information, you may unsubscribe by the means stated in the messages or contact us to unsubscribe.


We may use your personal information (including your device information, member information, account information, order information, and other information for which we have obtained your authorization) for carrying out analysis of consumer preference so as to further promote the quality of commodities and services. We may push, on the basis of the analysis results, marketing advertisements and special offer information in which you may be interested on our Network Platforms and third-party platforms or applications. If you do not want to receive such information, you may disable the information receiving feature or unsubscribe by the means stated in the messages or according to the information displaying rules of the third-party platform concerned.


(11) Participation in survey, interaction, or other activities

If you participate in any survey or interact with us by other means, we will collect your relevant information and other information relating to the topic in which you may be interested from you with your consent.


We may also collect, use and process your information with your consent by other information (such as the curriculum vitae that may be submitted online to apply for a job with us) relating to a specific event or activity


(12) Indirect collection of personal information by us

To protect the security of your account, confirm the transaction status, provide after-sales service for you, or resolve a dispute, we may obtain your personal information from any third party (for example, we may collect the information about your transaction, payment, or booking which is related to the transaction process through the transaction counterparty selected by you or any third-party information system or payment agency directly involved in the transaction so that we can process your order better and ensure successful completion of the transaction or better prevent malicious acts, such as fraud and click farming). We will collect such information from our cooperative partners in accordance with laws, regulations, and our agreements with third parties as well as the provisions of this Policy.


(13) Improving our products and services

During the period of your use of the Network Platforms, in order to meet the reasonable needs for carrying out data analysis and improving our products and services, we may collect and use your member information, order information, device information, other service log information relating to our products and services (including browsing history, clicking and viewing history, searching and inquiring history, transaction information, IP address, browser type, telecom operator, language used, date and time of access, and etc.), as well as other relevant information that we may obtain with your authorization when you interact with us, our affiliate, or our cooperative partner.


In accordance with applicable law, if we take technical measures to process personal information in such a way that such information cannot be re-identified to a specific individual and cannot be recovered, we may use such information for statistical and analytical purposes and may share such statistical information with third parties to improve our products and services, and to support business decisions, without separate notice to you and without your consent.


We may collect your personal information from third parties to enrich our understanding of you in order to improve the products and services we provide to you. We will confirm the legitimacy of the source of such personal information and the scope of authorized consent, and will seek your consent anew when such use exceeding your authorized scope.


(14) Safety management

In order to control safety risks, ensure safe operating environment and identification of abnormal state of member accounts, better protect the personal and property safety of you, other users, or the general public from being harmed, better prevent safety risks such as phishing, fraud, network vulnerability, computer virus, network attack, and network intrusion, and identify any violation of any laws, regulations, or relevant Pernod Ricard rules more accurately, we may use or integrate your location information, member information, order information, device information, other service log information relating to our products and services, as well as the information shared by our cooperative partners upon your authorization or according to law to comprehensively evaluate the risks in your account and transactions, verify identity, test and prevent security incidents, and take necessary recording, investigating, auditing, analyzing, and treating measures according to law. If you refuse the recording of the aforementioned information by us, we may be unable to ensure the account security of you and other users.


1.2Circumstances under which you may make a choice about whether or not to authorize us to collect and use your personal information


Realization of additional features and services: In order to provide more convenient, better, and personalized products and/or services for you, we may collect and use your personal information when you interact with us and use the following additional features. If you do not provide such information, you may be unable to use such additional features or services to be provided for you, without affecting your use of other services or features. Such additional features include:


(1) Geographical location-based information display: After you enable location permission, we will obtain your location information and send to you the information about the events carried out at your place according to your location information. In addition, when you use some of the Pernod Ricard Mini Programs (such as the WeChat applet "Pernod Ricard Le Code+"), we may request location permission and collect your location information to know our customers and ensure fair and just benefit events provided by us, however, that your refusal to provide location information will not affect your participation in the events. You may disable location permission in your device system to stop our collection of your location information, but you may be unable to use the geographical location-based services to be provided by us or achieve the expected effect of relevant services if you have done so.


(2) Camera-based additional features: You may use such additional features to realize the code canning or participate in our relevant marketing and promotion events. It should be noted that, even if you have agreed to enable the camera permission, we will obtain relevant information by the camera or album only when you click the above features on your own initiative. You may disable such permission if you do not intend to use such features.


(3) Album permission-based additional features: You may choose to enable, by voluntary uploading of images or videos, the album permission in the system to authorize us to access your album so that you can post content or communicate with the customer service staff online by uploading photos or videos. We will collect the above-mentioned information that you have uploaded and you may disable such features in your system permission, in which case you may be unable to upload photos or videos.


(4) Action and direction permissions-based additional services: In order that you can have immersive experience, we may apply for your action and direction permissions on some of the Pernod Ricard Mini Programs (such as the WeChat applet "Absolute").


(5) Microphone-based additional services: you may contact the customer service by sending voice message so as to improve your customer service experience. If you choose to disable the microphone permission, you will be unable to use such voice customer service, but you can still contact the customer service by other means.


Notes: due to the differences between platforms, devices, systems, and between the services provided by us, (1) the permissions to be obtained on the Pernod Ricard Mini Programs and the forms of notifications may vary slightly from Pernod Ricard APP to Pernod Ricard APP, subject to the page tips on the platform being used by the APP then; (2) the forms of permission tips, display, and disabling may vary from device from device or from system to system, subject to the instructions or guide given by the device or system developer concerned.


All above permissions will not be enabled by default. We will obtain your confirmation before enabling such features and you may check the enabling of such permissions one by one by the setting of your device system and decide to enable or disable such permissions from time to time. Even if we have obtained such permissions upon your authorization, we will not collect or use your information when such information is not necessary for relevant feature or service.


1.3 According to relevant provisions, we may collect, use, share, transfer, or publicly disclose your personal information according to law without your consent under the following circumstances

  • Such information is necessary for the execution or performance of a contract by you as a party;

  • Such information is necessary for the performance of legal duties or obligations;

  • Such information is necessary for coping with public health emergency or protecting a natural person's life, health, and property safety in emergency;

  • The personal information will be processed to the reasonable extent for reporting news or carrying out supervision by public opinions for public interests;

  • The personal information, that has been made public by an individual on his/her own initiative or legally made public otherwise, is processed to the reasonable extent in accordance with the Personal Information Protection Law; and

  • Other circumstances as stipulated by laws or administrative regulations.


2. How we share, transfer, publicly disclose, or entrust others to process your personal information

2.1 Sharing

In principle, we will not share your personal information with other companies, organizations, or individuals, unless your personal information is shared as follows:

  • Sharing with your express consent: to meet the needs for specific business scenario, we will share, with your express consent, your personal information with others. If we need to share your information with any third party to provide any service for you, we will evaluate the legality, legitimacy, and necessity of collection of information by such third party and obtain your consent by any means such as confirmation of agreement or copywriting confirmation in the specific scenario or pop-up window tips or make sure that the third party has obtained your consent.

  • Legal sharing: we may share your personal information in accordance with the requirements of laws or regulations, for meeting the needs for dispute resolution, or as required legally by any administrative or judicial organ.

  • Sharing according to your voluntary choice: if you use, purchase, or enjoy commodities and services by the Network Platforms, we will share member information, order information, location information, and the device information that is related to, and necessary for, the transaction with the suppliers of the commodities and services concerned according to your choice so as to realize your transaction and meet the needs for logistics delivery and after-sales services.

  • Sharing with the legal entities and affiliates under Pernod Ricard Group: in order to provide our products and services for you, carry out internal analytical research and financial accounting, recommend the information in which you may be interested, identify the abnormity of the member account, and protect our affiliates, brands of Pernod Ricard, and the personal and property safety of other consumers of Pernod Ricard or the general public from being harmed, your personal information may be shared with our affiliates. We will share necessary personal information only and limit the sharing of such personal information to the purposes stated herein. Please refer to the Preface for the list of domestic legal entities of Pernod Ricard Group.

  • Sharing with authorized cooperative partners: we may entrust or authorize our cooperative partners to provide certain services for you or perform responsibilities on behalf of us and we may share with our business partners member information, order information, location information, device information, and etc. that may be necessary for providing services for you. We will share your information only for legal, legitimate, necessary, specific, and express purposes stated herein. Our authorized cooperative partners may have access only to the information that is necessary for performing their responsibilities and shall not use such information for any other purpose. Our authorized cooperative partners mainly include:

1.  Authorized cooperative partners for commodities or technical services. We will share your necessary personal information with the suppliers that support our features. The aforementioned support includes supply of commodities or provision of technical services, logistics delivery services, and payment services, issuance of cards and coupons, data processing, and etc. We share such information for the purpose of realizing the basic features of our products or services (for example, we must share your necessary order information with a logistics service provider to arrange delivery).

2.   Suppliers of advertisements or services. Unless permitted by you, we will not share your personal information (which refers to the information that may be used to identify you, such as name or mobile phone number by which you may be contacted or identified) with the suppliers of advertisements or services.

3.   Suppliers of survey analyses. We may share your personal information (such as mobile phone number and order information) with the suppliers of survey analyses so that we can understand your needs and preferences better and provide more suitable and more accurate services for you.

Please note that we will share your personal information only for legal, legitimate, necessary, specific, and express purposes and execute the protection and confidentiality terms and conditions on relevant information with the companies, organizations, and individuals with which/whom we share personal information for the purposes stated herein only to require them to abide by agreements and take relevant security measures to protect your personal information.


2.2 Transfer

We will not transfer your personal information to any company, organization, or individual, unless:

  • We have obtained your prior express consent or authorization for such transfer;

  • Such transfer is carried out as required by applicable laws, regulations, legal procedures, or administrative or judicial organ; or

  • Personal information is transferred in any merger, acquisition, asset transfer, or similar transaction, in which case we will require the surviving company or organization that may possess your personal information to be bound by this Policy. Or else, we will require such company or organization to obtain authorization or consent from you anew.


2.3 Disclosure

We will not disclose your personal information, except the necessary public disclosure of your personal information made for publishing the winning account number in a lucky draw or with your express consent. However, we may disclose your personal information to the competent authority in accordance with laws or the mandatory requirements of a judicial organ or an administrative organ provided that we will require the party that requires us to make such disclosure to issue corresponding valid legal document and take necessary security measures for the disclosed information.


2.4 In accordance with relevant laws, regulations and national standards, we do not need your consent to share, transfer or publicly disclose your personal information under the following circumstances:

  • where it is necessary for the conclusion and performance of a contract under your request；

  • where it is necessary for us to perform statutory obligations；

  • where it is necessary for the responds to a public health emergency or for the protection of the life, health and property of the safety of you and others in any emergency；

  • where such acts as news reporting and supervision by public opinions are carried out for the public interest, and the processing of your personal information is within a reasonable scope；

  • where it is necessary to process your personal information disclosed by you or has been legally disclosed within a reasonable scope;

  • other circumstances prescribed by laws and administrative regulations.


3. How we retain your personal information

We will retain your personal information in strict accordance with the principle of minimum term. Where there are any express provisions of applicable laws or regulations on the term during which we may retain your personal information, we will abide by such provisions; where there are no such express provisions, we will retain your personal information unless and until: (1) all the purposes of collection, use, and sharing of your personal information by us have been accomplished; (2) you terminate your use of our products or services or will never participate in our events. For example, if your member account has been inactive for more than five consecutive years, we will delete from our system or de-identify your account and the personal information related thereto in time; or (3) you require us to delete your personal information explicitly. After the term of personal information retention expires, we will delete, anonymize, or otherwise process such personal information as permitted by laws or regulations.


4. Your personal information rights

4.1 Inquiry about your personal information

  • Account information: you may view your account information by "Personal Data" and "Address Book" on the page "User Information" of the Pernod Ricard Websites or "Information Management" on the page "Mine" of the Pernod Ricard Mini Programs.

  • Member information: you may view your member information by the module relating to member information management on the Pernod Ricard Websites or the Pernod Ricard Mini Programs.

  • Order information: you may view your order information by the page "My Orders" of the Pernod Ricard Websites or "All Orders" on the page "Mine" of the Pernod Ricard Websites.

If you need to have access to any other personal information, that cannot be accessed by the above-mentioned means, due to any operational problem in the process of your visit, you may contact us by the means stated herein.。


4.2 Correction/updating of your personal information

  • Account information: generally you may correct your account information by "Personal Data" and "Address Book" on the page "User Information" of the Pernod Ricard Websites or "Information Management" on the page "Mine" of the Pernod Ricard Mini Programs.

  • Member information: generally you may correct your member information by the module "member information management" on the Pernod Ricard Websites or the Pernod Ricard Mini Programs.

  • Order information: if the order information submitted by you is incorrect, you may edit and modify such information by the customer consulting hotline (400-690-0082)/the interaction with the on-line customer service staff.


We cannot provide the service of access to or correction of some of your personal information, except the above-mentioned information, which mainly includes your device information collected for improving your user experience and ensuring transaction security and the partial personal information generated from your use of additional features. We will use such information only to the extent authorized by you and you cannot access or correct such information, but you may contact us by the means stated herein so that we can modify, delete or anonymize such information for you.


4.3 Change of the scope of your authorization or consent or withdrawal of your authorization

If you want to change or withdraw your authorization permitting us to continue collecting and using your personal information, you may delete the information or disable device features to change the scope of authorization permitting us to continue collecting the personal information or cancel your authorization. In addition, you may withdraw your overall authorization permitting us to continue collecting your personal information by cancelling the account. You should understand that basic personal information is necessary for realizing certain features and, after you have changed or withdrawn your consent or authorization, we may be unable to continue providing the services corresponding to the changed or withdrawn consent or authorization for you, nor will we process your corresponding personal information. However, your decision to change or withdraw your consent or authorization shall not affect our prior processing of personal information based on your consent or authorization.


If you do not want to receive marketing advertisements and special offer information pushed by us, you may unsubscribe the information by the means stated in the messages, or disable the notification authorization of Network Platforms through mobile phone, or contract us by the means stated in this Policy.


4.4 Deletion of your personal information

You may contact us to request us to delete personal information by the means stated herein if:

  • Our processing of the personal information is in violation of any laws or regulations;

  • We have collected or used your personal information without your consent;

  • Our processing of the personal information is in breach of any agreement with you;

  • The purposes of processing your personal information have been achieved, cannot be achieved, or become unnecessary (for example, you will never use our services or you have cancelled your account);

  • We will never provide services for you; or

  • You have withdrawn you authorization of or consent to processing of your personal information by us.


Please note that, after you have deleted relevant information by yourself or under our assistance, we may be unable to delete such information immediately from the backup system due to the limitation of applicable laws and security technologies and we will store your personal information in a secure manner and prevent it from being further processed unless and until the backup can be eliminated or anonymized.


4.5 Cancellation

If you want to cancel your Pernod Ricard member account, you may contact us by the means stated in this Policy. After having verified your identity and formally started the account cancellation procedure, we will stop the provision of products or services for you and delete, anonymize in accordance with applicable laws or regulations, or process your personal information by other means specified by laws. Please note that you should read and understand the relevant cancellation contents carefully of Member Rules before cancellation, no matter which form of cancellation you select.


4.6 Obtainment of the copy of your personal information

If you need to obtain a copy of your personal information that has been collected by us, we may respond, as appropriate, to your request if such response is in line with applicable laws and technically feasible.


4.7 Constraint of automatic decision-making by the information systems

In certain business features, we may only rely on the decisions made by the unartificial and automatic decision-making mechanisms such as information systems and algorithms. If such decisions affect your lawful rights or interests significantly, you have the right to require us to make explanation and we will offer appropriate remedy.


4.8 Response to your request

If you are unable to perform rights by the above-mentioned means, or think that we have violated any laws or regulations or breached the agreement with you on the collection or use of personal information, you may contact us by the means stated at the end of this Policy.


In order to ensure the security of personal information, we may carry out necessary identity verification when we respond to your request. In general, we will give a reply to your request within fifteen days upon receipt of your feedback and verification of your identity unless laws or regulations require otherwise. In addition, you should understand and acknowledge that we will be unable to give a reply to your request if:

  • Such personal information is related directly to state security or national defense security;

  • Such personal information is related directly to public security, public health, or major public interests;

  • Such personal information is related directly to criminal investigation, filing of a lawsuit, trial, or enforcement of judgment;

  • There is sufficient evidence indicating that you have subjective malice or have misused your right;

  • Our purpose of collecting or using such personal information is to safeguard your or other individuals' material legal rights and interests, such as life and property, but it is difficult to obtain your authorization or consent;

  • Response to your request will cause serious damage to the lawful rights or interests of you, any other individual, or any organization;

  • Such personal information involves trade secrets; or

  • Other applicable circumstances specified by laws or regulations exist.


In principle, your reasonable request is free of charge. But, we will charge, as appropriate, certain fee before responding to your request that has been repeated again and again beyond reasonable scope. We have the right to reject any request that is repeated for no reason, needs too many technological means (such as development of new system or fundamental change of existing practices), endangers any other person's lawful rights or interests, or is highly impracticable.


5. How we use Cookies and similar technologies

Cookie and other similar device information identification technology are widely used in the Internet. When you use the Pernod Ricard Websites, we (or third party authorized by us) may use related technologies to send one or more cookies or anonymous identifiers (hereinafter collectively referred to as "Cookies") to your device to collect, identify and store information when you access our Network Platforms. We undertake not to use Cookies for any purpose other than those stated in this Policy. We use cookies mainly to ensure the safe and efficient operation of our products and services, enabling us to confirm the security status of your account and transaction, check the abnormal situation related to crash and delay, and save you the steps and processes of filling in forms and entering search contents. At the same time, we may use these technologies to better understand user behavior and preferences, use Cookies to show you information or features that may be of interest to you, and optimize your selection of advertising.


In order to obtain the full list of the third parties that have accessed your web browser (by the Network Platforms or other means), we recommend that you install the web browser plug-in that may realize such purpose. Most browsers provide users with the function of clearing browser cache data, you can perform corresponding data clearing operations, and you may select the mode that your computer will give a warning each time when a Cookie is sent or disable all Cookies. You may finish the aforementioned operation by the browser settings on your browser and device. Browser setting operations may vary from browser to browser. Please view the help menu of your browser to understand the correct method of changing the settings concerning your Cookies. If you disable Cookies, you may be unable to use many features that can assist our Network Platform in more efficient operation and some of our service will not function normally.


The use of Cookies on WeChat mini programs are subject to Tencent's cookies policy https://privacy.qq.com/policy/cookie-privacypolicy。


6. Cross-border transmission of personal information

All personal information that has been collected by us or generated in the territory of the People's Republic of China is stored in the territory of the People's Republic of China. However, we may need to share with, or transfer to, any third parties located in any country or area outside China your personal information under certain special circumstances to perform and provide the services of Pernod Ricard. The privacy-related laws of such country or area may be different from those of China. We will abide by personal information protection-related laws of China, acquire your separate consent for cross-border transmission of personal information, and try our best to ensure that the third parties that have access to your personal information take similar and/or comparable personal information protection measures. We will carry out regular security evaluation for cross-border transmission of personal information, if such regular security evaluation is required explicitly by applicable laws, and decide whether or not to continue the cross-border transmission of your personal information according to the evaluation results.


7. External provision and link to other websites

Our websites and applications may contain the links to third-party websites, products, and services. In addition, the products or services sourced from third-party platforms may be used or provided by our services. The aforementioned third parties may collect, use, and process your personal information, but this Policy does not apply to them. Please be sure to read carefully and understand such third parties' respective terms and conditions on privacy protection. If you find any risk in the links to such third-party websites, products, or services, you should terminate relevant operations so as to prevent your rights and interests from being harmed.


8. How we protect your personal information

We attach great importance to your personal information. To this end, we take various security measures, including formulation of reasonable information security management policies, implementation of security technologies, and etc., to minimize the risks of unauthorized access, use, modification, disclosure, damage, and deletion of your personal information. Such measures include but are not limited to the following:

  • In the process of information transmission, we carry out encrypted transmission of the information input by you so as to minimize the risk that such information is captured;

  • When transmitting or retaining sensitive personal information, we take various security measures, such as encryption, access control, and de-identification, to ensure the security of transmission or retention;

  • We strictly control the access to our data center so as to prevent your information from being accessed or used without authorization; and

  • We have set up a dedicated information security team to promote and ensure the security of personal information and have also established various policies and procedures for data classification, data security management, development of data security, emergency response, and etc.to manage and regulate the retention and use of personal information.


It should be noted that there is no absolutely secure information environment in the real world. In particular, under certain special circumstances, there is still the risk of disclosure or loss of personal information (such as hacker attack) though we have taken various security measures. Therefore, please take positive measures to ensure the security of personal information, for example, do not disclose your personal account and information to others, do not provide your personal information to us or any third party that provides services for you in our name in any unreliable information environment so as to protect your personal or property safety.


After you terminate your use of our products and services, we will stop collecting and using your information (unless otherwise required by laws, regulations, or regulatory authorities). If we cease relevant services or operations, we will stop collecting your personal information in time and notify you of the stopped operation in advance by one-by-one delivery, public announcement, or other proper means. After relevant services or operations have been terminated, we will delete or anonymize your personal information in our possession, or process it by other means in line with applicable laws and regulations.


If we are informed of any personal information security incident, we will notify you of such incident through as many channels as possible according to the requirements of laws and regulations. If it is difficult to notify you by one-by-one notification, we will publish a public announcement in a reasonably practicable manner. In addition, we will report the handling of personal information security incident to the competent regulatory authorities as required by them.


9. Updates and scope of application of this Policy and governing law

This Policy is updated and enters into effect on the date first written above. This Policy is our generally applicable personal information protection policy. Notwithstanding the forgoing, some specific services are subject to special personal information protection policy and the same constitutes an integral part of this Policy. If there is any discrepancy between such special personal information protection policy and this Policy, such special personal information protection policy shall prevail.


We will update this Policy from time to time. Without your express consent, we will not limit your rights under this Policy. If this Policy is updated by us, we will release the updated version of this Policy on all Network Platforms. If such update leads to substantial reduction of, or material changes to, your rights under this Policy, we will notify you by prompts at conspicuous positions, push messages sent to you, or other means before this Policy becomes effective. By continuing the use of our services, you agree that you have read fully and understand and agree to be bound by this Policy as revised.


If you disagree to our revision of this Policy, please stop using relevant products and services immediately. By continuing the use of our products or services after this Policy is updated, you agree that you have read carefully and fully understand and agree to be bound by the updated version of this Policy.


This Policy applies only in the mainland of China, except Hong Kong, Macau, and Taiwan, and shall be governed by the laws of the People's Republic of China (without regard to the conflict of laws principles thereof).


10. Contact us and dispute resolution

If you have any questions, advice, or suggestions about this Policy or want to file a complaint or report anything with respect to this Policy, you may contact us by the following means:

Pernod Ricard customer consulting hotline: 400-690-0082 (working hours: 10:00 a.m. to 5:00 p.m. each day)

Email: Privacy-China@pernod-ricard.com

Mailing address: 6/F (Building C), No. 15, Lane 458, Madang Road, Huangpu District, Shanghai


Our department that is responsible for individual information protection and its contact information: the personal information protection team of Pernod Ricard China, whose mailing address is at 5/F (Building C), No. 15, Lane 458, Madang Road, Huangpu District, Shanghai, phone number is 400-690-0082, and E-mail address is Privacy-China@pernod-ricard.com。


With respect to your questions, advice, or suggestions, in general, we will give you a reply within fifteen days upon verification of your identity as a user. Please note that we may refuse to give any reply to any question about neither this Policy nor your right to personal information.


If you are dissatisfied with our reply, in particular, you deem that our processing of personal information harms your lawful rights or interests, you may file a complaint with the competent administrative organ or file a lawsuit with the people's court having jurisdiction over our domicile.