“Havana Club International, S.A. is a Cuban-French joint venture, established under Cuban law, and with registered office at Calle A No. 309 % 13 and 15, Plaza de la Revolución, Havana, Cuba.
Havana Club International, S.A. is the Data Controller of any Personal Data submitted to the Site. Pernod Ricard, in its role as Data Controller, respects your right to privacy when using the Site and communicating with us electronically.
- WHAT TYPE OF PERSONAL DATA DO WE COLLECT ABOUT YOU AND HOW DO WE DO IT?
We will only collect your Personal Data for the purposes listed in section 3 and each time you use any of the features or services provided by our Site.
The types and amount of information collected for the functions and services mentioned above may be updated and vary depending on the activities of Pernod Ricard and its affiliated companies.
Consistent with applicable legal obligations, we may employ various technologies that collect and report information about how you access and use our Site. In addition, we may use demographic information about users of our Site, which we may obtain from third parties such as Google or the social networks you use (“Usage Information”). Usage information may consist of the pages you have visited, how long you have been on them, what information about beverages or other content you have viewed or provided and in what language, including demographic information about you (age, gender and areas of interest, when this information is available) and which pages you searched for before viewing the current page, etc.
- HOW AND WHY DO WE USE TRACKING TECHNOLOGIES?
- Havana Club International, S.A. uses technologies such as cookies, IP address and log files in order to collect certain information such as browser type and operating system, referring page, itinerary within the Site, ISP domain, etc., with the purpose of improving the use and functionality of our Site and to better understand how visitors use our Site and the tools and services offered on it. Tracking technologies help us tailor our Site to your personal needs.
- An IP address is a number used by computers on a network to identify your computer each time you connect to the Internet. We may keep track of Internet Protocol (IP) addresses to (among other things): (i) troubleshoot technical problems, (ii) keep our Site safe and secure, (iii) restrict access to our Site to comply with applicable law or contractual restrictions and (iv) better understand how the Site is used.
- We (or a third party on our behalf) may collect information in the form of log files that record activity on our Site and collect statistics about user browsing habits. These entries are generated anonymously and help us collect (among other things) (i) the user’s type of web browser and operating system, (ii) information about their session (such as the URL from which it came, the date and the time you visited our Site and what pages you viewed and for how long) and (iii) other similar data about click and browsing patterns. We also use information captured in log files for our internal marketing and demographic studies so that we can constantly improve and personalize the online services we offer. Log files are used internally and are not associated with a particular user.
3. FOR WHAT PURPOSES DO WE USE PERSONAL DATA AND ON WHAT LEGAL BASIS IS IT BASED?
We collect user information to:
• Respond to your service request or perform a contract
- When you register or log in to our Site (mobile application, websites, social networks, etc.), Personal Data is used to offer you the relevant features and services to which you are subscribed, and to offer you the benefits and privileges normally associated with registration (eg, receiving selected communications at registration, invitation to events, participation in sweepstakes, etc.).
- When you purchase products on our Site, we use your Personal Data to fulfill your order and deliver the products to you.
- Send you transactional or administrative communications (eg, confirmation email when registering or unsubscribing, on a specific registration or activity), as well as certain announcements related to services (eg, notices about updates in notifications privacy, discontinued features or programs on our Site, changes to our online services or support policies, or other related changes)
- Allow us to send you marketing communications, provided you have given us your consent.
- In addition to the purpose for which the Personal Data was submitted, the option (in a box or similar) to use the user’s Personal Data for an activity or service other than the primary activity or service being requested may also be available. For example, if you register for a contest or other promotion, you may also be invited to subscribe to newsletters or alerts from our Site that host advertising 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” function, this Personal Data is used only to send the communication and will no longer be kept by us, in accordance with the applicable local legislation.
- When you use a QR code or equivalent feature displayed on Pernod Ricard products, we use your Personal Data to send you more information about the products where the QR code or equivalent feature was displayed, or about other products.
- Because it is also in Havana Club’s International, S.A. legitimate interest to provide you with a better service:
- Subject to your consent where necessary, we may from time to time combine, update or otherwise enhance the Personal Data collected through our site with data we receive from external registries or third parties. For example, we may combine survey or purely demographic information (e.g., age, gender, family, and other interests) not linked to any User Personal Data with Personal Data collected in our offerings (such as during registration from account). We may combine the above information and/or demographic information for our internal marketing and demographic studies and to constantly improve, personalize and tailor the products and services we offer to better meet user needs. Some tools we use involve automatic individual decision-making subject to applicable law. Opinions, questions or comments through our “Contact Us” form and our “Tell Us” compliance notification system: If you contact us through an online form, your Personal Data will be used to respond to your request. question or comment.
- We will ensure that User Personal Data is kept accurate, up-to-date and not duplicated in our database by verifying each of your interactions with us and/or one of our affiliates to ensure that Personal Data remain accurate or, if necessary, be supplemented/updated with additional information provided.
Havana Club International, S.A. may process Personal Data involving automated decision-making, including for the performance of a contract (e.g. to prevent fraudulent payments) or subject to the user’s explicit consent, in order to better serve your needs in accordance with your preferences.
Please note that automated tools are regularly checked to ensure that Personal Data is processed fairly. Specific measures are implemented such as data minimization when creating profiles. The user is invited to express her opinion through the right of access described above. You can also object to the result of the automatic decision by sending an email to the contact details described in Section 11 below.
- WHAT HAPPENS IF YOU REFUSE TO PROVIDE US WITH YOUR PERSONAL DATA?
If you choose not to submit Personal Data when requested, you may not be able to participate in certain activities or use some personalized features and other Site services and special services offered to you may also be limited. For example, if you decline to share your email address, you will not be able to receive newsletters or register with our Site. However, to simply browse our Site and learn more about Havana Club, you do not have to provide us with any Personal Data. In any case, we will always inform you of the Personal Data necessary to take advantage of the service.
- TO WHOM DO WE TRANSMIT YOUR PERSONAL DATA AND WHY?
Within the Havana Club International, S.A.
Havana Club International, S.A. may share your Personal Data for the purposes mentioned in Section 3 with its subsidiary companies, that is, companies over which Pernod Ricard has direct or indirect ownership control (collectively, the “Pernod Ricard Group”).
With third parties
Havana Club International, S.A. may also share your Personal Data with third parties, but only in the following situations:
- For marketing purposes if you have given us your consent. For support purposes: We may use service providers, agents or contractors, to ensure the internal operation of our Site and to assist us with the administration of our Site or the various features, programs and promotions made available to them. Any such third party must at all times provide the same levels of security for your Personal Data as Havana Club International, S.A. and, where necessary, will be bound by a legal agreement to maintain the privacy and security of Personal Data and process it only under specific instructions Havana Club International, S.A.
- For joint sponsorship programs and promotional purposes: when we launch a joint sponsorship program or promotion on our Site with another company, organization or reputable partner; As part of this event, we collect and process Personal Data and may share it with our partner or sponsor, subject to your consent where necessary. If your Personal Data is being collected (or shared with) by a company other than Pernod Ricard as part of any promotion, we will let you know at the time it is collected;
- For litigation and security purposes: We may also disclose your Personal Data if required to do so by law, or in our good faith opinion, such action is reasonably necessary to comply with legal process, to respond to any claim or to protect the safety or rights of Havana Club International, S.A., its customers or the public;
- In the event of a merger or acquisition of all or part of Havana Club International, S.A. by another company, or in the event that Pernod Ricard is about to sell or eliminate all or part of Pernod Ricard’s business, the buyer will have access to the information held by the Havana Club International, S.A. company, which may include Personal Data, subject to applicable law. Similarly, Personal Data may be transferred as part of a corporate reorganization, insolvency proceeding or similar event, if permitted by and in accordance with applicable law;
6. IS YOUR PERSONAL DATA SENT TO RECIPIENTS LOCATED IN OTHER COUNTRIES? WHY?
Havana Club International, S.A. is a company with the participation of Pernod Ricard and your Personal Data may cross international borders. They may be transferred to countries that have different legal levels of data protection than the country from which the Personal Data was sent. Your Personal Data may also be transferred between different companies of the Pernod Ricard group located in different countries. Pernod Ricard takes appropriate measures to maintain the security of Personal Data during transit and at the receiving location by implementing contractual clauses set forth by the European Commission and in accordance with the requirements of applicable law.
Our primary service providers for the operation of our Site are based in the European Union and the United States. The transfers of Personal Data to these service providers are implemented in accordance with the applicable legislation and are covered by the contractual clauses established by the European Commission or in the Privacy Shield between the European Union and the United States. These service providers are also bound by a contract that guarantees a high standard of privacy protection and requires (among other provisions) that they act only on Havana Club International’s, S.A. instructions and implement all necessary technical measures on an ongoing basis to maintain privacy. security of personal data.
7. FOR HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will store in our databases the Personal Data that you submit to us through our Site for as long as your account is active, for as long as the contract with you is in force or as necessary to provide you with the services you have requested or to answer questions or solve problems, or to provide better and new services. We may also retain your Personal Data in accordance with our internal retention procedure to the extent necessary to comply with our legal and regulatory obligations, to resolve disputes, to enable us to perform our contracts and for similar records management purposes. Thus, we may retain your Personal Data after you have stopped using Havana Club International, S.A. services or our Site, subject to the statute of limitations.
8. HOW DO WE PROTECT YOUR PERSONAL DATA?
Havana Club International, S.A. will take all necessary technical and organizational measures to protect the privacy and security of Personal Data collected through our Site, including Sensitive Personal Data. Such measures consist, among others, of: (i) storing your Personal Data in secure work environments not accessible to the public, but only to authorized members of the Pernod Ricard Group staff and our agents and contractors and (ii) verifying the identity of registered users before they can access their Personal Data.
9. WHAT ARE YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA?
You can access the Personal Data we process about you by contacting the Havana Club International, S.A. Privacy Office at HC_contact@havana-club.com . You may also contact the Privacy Office to express the following choices:
- If your Personal Data has been processed with your consent, you can withdraw that consent at any time, without affecting the lawfulness of the processing based on the consent before its withdrawal. You can request access to your Personal Data;
- You may request to rectify your Personal Data if it is inaccurate, incomplete or out of date;
- You may request deletion of your Personal Data if (i) your Personal Data is no longer necessary for the purpose of data processing, (ii) you have withdrawn your consent to data processing based solely on such consent, (iii) you have refused the data processing, (iv) the processing of Personal Data is unlawful, (v) the Personal Data must be erased in order to comply with the legal obligation applicable to Havana Club International, S.A. Havana Club International, S.A. will take reasonable steps to inform the other entities of the Pernod Ricard Group of such removal;
- You can request the restriction of processing (i) in case the accuracy of your Personal Data is in dispute in order to allow Havana Club International, S.A. to check its accuracy, (ii) if you wish to restrict your Personal Data instead of deleting it, despite that the processing is unlawful, (iii) if you want Pernod Ricard to keep your Personal Data because you need it for your defense in the context of legal claims (iv) if you have refused the processing, but Havana Club International, S.A. checks to see if you have legitimate grounds for such processing which could override your own rights if the processing is based on the legitimate interest of Havana Club International, S.A.;
- You can request the portability of the Personal Data provided if the processing of the Personal Data is based on your consent or the performance of a contract and is carried out in an automated way (eg, excluding paper files).
- You always have the option not to share your Personal Data with us. If you choose this option, you may be limited in the activities and features that we can offer you.
- You have the right to object to our processing of your Personal Data at any time, for direct marketing purposes or profiling-based marketing purposes, or if the data processing is based on the legitimate interest of Havana Club International, S.A. (except if we can demonstrate compelling legal groundsfor such processing).
10. HOW DO WE TREAT THE PERSONAL DATA OF MINORS?
11. DO WE LINK TO OTHER THIRD PARTY WEBSITES?
Our Site 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 who may use our logos as part of a co-branding agreement. We have no control over these third parties, and use of their websites and features are subject to the privacy policies posted on those sites. We are not responsible for the privacy practices or business practices of any third party website. Therefore, you should pay attention to and review the applicable privacy policies of those third-party websites you visit before submitting Personal Data.
12. HOW CAN YOU CONTACT THE RELEVANT SUPERVISORY AUTHORITY?
Havana Club International, S.A
Calle A No. 309 entre 13 y 15. Plaza de la Revolución.
Or sending an email to: HC_contact@havana-club.com