“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.
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.
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
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.
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.
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:
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:
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