ONLINE pRIVACY POLICY

“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. respects your right to privacy when using the Site, which can be accessed at www.havanaclubmuseum.com (the “Site”), and when communicating with us electronically. This Privacy Policy is intended to inform you of how Pernod Ricard (“Pernod Ricard”, “our”, “ours” or “we”) collects, stores, uses and processes the Personal Data you provide to us. through the Site.

Before using our Site, please read this Privacy Policy (including the Cookie Policy, see Section 2) carefully. In the event that you do not accept this Privacy Policy or the Cookie Policy, please do not use the Site. We reserve the right to make changes to this Privacy Policy or the Cookie Policy at any time. We will notify you of such changes by posting them to this Privacy Policy or Cookie Policy. We also encourage you to periodically review this Privacy Policy and Cookie Policy to ensure you are aware of any changes and how your information may be used. If you continue to use the site, we will consider that you accept these changes.

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.

1. WHAT TYPE OF PERSONAL DATA DO WE COLLECT ABOUT YOU AND HOW DO WE DO IT?

Personal Data for the purpose of this Privacy Policy means any information that can be used to personally identify or contact the user via the Internet or offline. This information includes data such as name, postal address, email address, telephone number, demographic information such as date of birth, age, gender, and habits or preferences regarding the linking of said data with personally identifiable information (collectively, “Personal Data”).

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.

2. 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.
• We use cookies to improve the use and functionality of our Site and to better understand how visitors use our Site and the tools and services offered on it. Subject to your consent, where required by applicable law, our Website uses cookies and similar technologies (“Cookies”). Cookies are small files that are placed on the user’s device and have a number of purposes such as allowing efficient navigation between pages, remembering preferences and, in general, improving the experience. The use of cookies on our Site allows you to enjoy a smoother visit and more accurately measures your behavior on our Site. You can find out more about what cookies we use and how to disable them in the Cookies Directive.
• 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.
  • We can carry out profiling based on monitoring the user’s browsing activities on our Site to better understand their preferences and main interests and adapt our marketing communications to their profile, unless they object in the established conditions in Section 9 of this Privacy Policy.

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.

3. 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.

4. 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 grounds for such processing).

10. HOW DO WE TREAT THE PERSONAL DATA OF MINORS?

Our Site is not intended for children under the legal drinking age (“Minor”), so we do not knowingly collect Personal Data from Minors. You must be at least 18 years of age to create an account and participate in activities and transactions on our Site. By creating an account or participating in activities or transactions on our Site, you confirm that you are at least 18 years of age and have the full capacity to accept, comply with, and be legally bound by our Terms of use and this Privacy Policy. If we are notified or become aware that a Minor has submitted Personal Data to us through our Site, we will delete such Personal Data.

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?

If you have any questions, complaints or comments regarding this Privacy Policy or our information collection practices, please contact us at:

Havana Club International, S.A

Calle A No. 309 entre 13 y 15. Plaza de la Revolución.

Havana, Cuba

Or sending an email to: HC_contact@havana-club.com

COOKIE DIRECTIVE

Subject to your consent where required by applicable law, our website uses cookies and similar technologies (“Cookies”).

This Cookie Policy (the “Policy”) describes how HCI (“HCI” or “we”) is committed to respecting your privacy in relation to its use of cookies on this website, accessible at www.havanaclubmuseum.com (the “Site”).

Before using our Site, please read the Cookie Policy (including the Online Privacy Policy) carefully. If you do not accept this Cookie Policy or the Pernod Ricard Privacy Policy, please do not use our Site.

We reserve the right to make changes to this Cookie Policy or the Pernod Ricard Privacy Policy at any time. Such changes would come into force in the near future in order to take into account the provisions on e-privacy regulations currently under discussion in the EU Parliament, as well as recommendations from data protection authorities.

Personal Data for the purpose of this Cookie Policy means any information that can be used to personally identify or contact the user via the Internet or offline. This information includes data such as name, postal address, email address, telephone number, demographic information such as date of birth, age, gender, and habits or preferences regarding the linking of said data with personally identifiable information (collectively, “Personal Data”).

We will notify the user, by appropriate means, of any material/fundamental changes to this Cookie Policy or Pernod Ricard’s Privacy Policy. We also encourage you to periodically read this Cookie Policy or Pernod Ricard’s Privacy Policy to ensure you are aware of any changes and how your Personal Data may be used.

1. WHAT IS A COOKIE?

Cookies are small text files that are stored on a user’s computer or mobile device (such as a smartphone or tablet) when visiting our Site. Cookies typically store the name of the web page/application the cookie came from, the duration of the cookie (i.e. how long it stays on your device), and a value, usually a randomly generated unique number.

2. WHY DO WE USE COOKIES?

Cookies make our Site easier to use and help us tailor our Site and products to users’ needs.

Cookies do this because our Site can read and write these files, allowing them to recognize users and remember important information that will make using our Site more convenient for you (for example, remembering user preferences).

Cookies may also be used to streamline future activities and user experience on our Site. We also use cookies to compile aggregate, anonymous statistics that help us understand how our Site is used and improve the content and structure of our Site.

3. WHAT ARE THE DIFFERENT TYPES OF COOKIES THAT WE USE?

• Persistent cookies are used to save users’ login information and remember their settings for future visits to our Site. A persistent cookie is a cookie stored as a file on the user’s computer, where it remains even after the browser is closed. These cookies can be read by the Site that created them the next time users visit the Site.
• Session ID cookies are used to enable certain features of our Site and service, to better understand how users interact with our Site, and to monitor aggregate usage and Internet traffic. Unlike persistent cookies, session cookies are removed from your computer when you close your browser. As a general rule, they store an anonymous session identifier on the computer, which means that users can browse a web page / application without having to log in on each page, for example.
• First party cookies are our own cookies that we use to improve the user experience. They are associated with the Personal Data of a user. No third party has access to the information we collect through our own cookies. • Third party cookies are cookies used by third parties on our Site to provide their services; this includes advertising cookies. Third parties place these cookies on our behalf on users’ devices when they visit our Site to help them provide their services. You will find more information about these cookies in the privacy policies of these third parties. Below is a list of the different types of cookies we use on our Site. To the extent that information collected through cookies constitutes Personal Data, the provisions in the Online Privacy Policy will apply in conjunction with this Cookie Policy. to. essential cookies Essential cookies are cookies that are strictly necessary for our Site to function and for users to use its services and features. In the absence of these cookies, our Site will not function properly as we would like and we may not be able to provide the Site or certain services or features of the Site that users request. We also use technical cookies to remember choices made on our Site (such as user name, language or the region in which users live) for personalization purposes. These cookies do not collect information about the user for advertising purposes or to remember their Internet browsing activity. These cookies are necessary for the operation of our Site and therefore their use cannot be refused.

These cookies are necessary for the operation of our Site. They are considered non-invasive privacy cookies that improve the Internet experience and, therefore, their use cannot be rejected.

1. Analytical cookies

Our Site may also use Google Analytics cookies. These third party cookies collect information about how users interact with our Site. For example, they track the most visited pages, Internet Protocol (IP) addresses, browser types, Internet Service Providers (ISPs), referring/exit pages, operating systems, date/time, and visit data. We use this information to analyze usage trends, administer our Site, track how users move around our Site, and gather general demographic information about who uses our website. Our Site uses the following analytical cookies:

To opt out of Google Analytics cookie tracking on any website, you can visit http://tools.google.com/dlpage/gaoptout. To stop being tracked only on this Site, use the cookie configuration tool: add a link.

4. HOW LONG ARE THE COOKIES STORED?

Cookies will have a maximum retention period after having placed them in the user’s terminal under the applicable legislation.

5. HOW TO CONTROL COOKIES ON OUR SITE?

Except for cookies classified as essential, the cookies described above will be installed on users’ computers only if they explicitly accept them. If you wish to choose them personally, use the link to the Cookie Configuration Tool: add a link, also accessible from the banner to accept/reject non-essential cookies from our Site. To do this, click the corresponding button when it appears in the menu as follows:

You can also control how your browser uses cookies. The browser’s “Help” function tells you how to do this. All cookies can be rejected in this way, except Javascript cookies. Please note that if you disable cookies, you may not be able to log in to your account, view content, or use other features of our Site, and parts of the Site may not work at all or behave in unexpected ways. If you use different devices to view or access our Site (e.g., a computer, smartphone, tablet, etc.), you will need to ensure that each browser on each device is adjusted to suit your viewing preferences. cookies.

6. HOW CAN YOU CONTACT US?

If you have any questions, comments or problems regarding the use of Cookies, please contact us at HC_contact@havana-club.com