PRIVACY POLICY

Personal Data is collected only for the purposes set out in Section 3 below and each time you use any of the features or services offered by our Digital Media.

The types and amount of information collected when using the above-mentioned features and services may be updated and vary depending on the activities of TAC.

Most of the Personal Data we process is directly collected from you, in particular whenever you fill out a form on our Digital Media or contact us. We also collect, with your consent, Personal Data concerning you whenever you browse on our Digital Media through the use of tracking technologies (in this respect see section 2 below as well as our Cookie Policy).

Subject to applicable law requirements, we may also use various tools that allow us to target the ads we display on social media. Your identity, contact and social media information (i.e. your profile data, social demographics, behavioral data and interests) are processed in this context.

TAC uses tracking technologies such as cookies, IP addresses or log files. Tracking technologies help us tailor our Digital Media to your personal needs and offer you content adapted to your interests.

• We use cookies to better understandhow visitors use our Digital Media and the tools and services offered, improve their use and functionality, and provide you content adapted to your interests. Subject to your consent where required by applicable law, our Digital Media use cookies and similar technologies (“cookies”). Cookies are small files that are placed on your device that serve a number of purposes such as letting you browse between pages efficiently, remembering your preferences, and generally improving your experience. The use of cookies on our Digital Media allows you to enjoy more seamless visits and more accurately measures your behavior on our Digital Media.
• You can learn more about the cookies we use and how you can disable cookies in the TAC Cookie Policy.
• An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet. We may keep track of Internet Protocol (IP) addresses to (among other things): (i) troubleshoot technical concerns, (ii) maintain website safety and security, (iii) restrict access to our Digital Media to comply with applicable law or contractual restrictions, and, (iv) better understand how our Digital Media is used;
• We (or a third party on our behalf) may collect information in the form of log files that record activity on the Digital Media and gather statistics about users’ browsing habits. These entries are generated anonymously, and help us gather information such as (i) a user’s browser type and operating system, (ii) information about a user’s session (such as the URL they came from, the date and time they visited our Digital Media, and which pages they’ve viewed on our Digital Media and for how long), and (iii) other similar navigational or click-stream data. We also use information captured in log files for our internal marketing and demographic studies, so we can constantly improve and customize the online services we provide you. Log files are used internally only, and are not associated with any particular user.

We collect information about you to:

• Respond to your request for services or to perform our contract (based on our legitimate interest, to carry our precontractual or contractual measures with you):

– When you register or sign up for our Digital Media (mobile app, websites, social media, etc.), your Personal Data is used to provide you with the relevant features and services you subscribe to, and to offer you the benefits and privileges that typically come with your registration (e.g. being invited to events, participating in a contest, etc.);

– Handle any claims or complaints you make about our products and/or services.

• Send you transactional or administrative communications (based on our legitimate interest or to carry out precontractual or contractual measures with you): (e.g. confirmation email when you sign up for, or unsubscribe from, a specific service or feature), as well as certain service-related announcements (e.g., notices about updates to our privacy notices, discontinued features or programs on our Digital Media, changes to our online services or technical support policies, or other related changes).

• Allow us to send you marketing information when you consent:

– We may use your Personal Data, with your consent, to send you announcements and promotional information about our products and services by email or by text messages. For example, if you are signing up for a contest or other promotion, you may also be invited to sign up for newsletters or alerts from our Digital Media hosting the promotion or from other websites.

– When you use the third-party sponsorship (“Send to a friend”) feature: the Personal Data collected is used only once to send the communication and is not further retained by us, as appropriate according to local law

– When you use a QR Code or equivalent feature displayed on TAC products: we use your Personal Data to send you more information on the products where the QR code or equivalent feature is displayed or other products.

• To fulfil our legitimate interest in better serving your needs:

– Whenever this new processing is compatible with the processing for which you have given your consent , we may occasionally combine, update, or otherwise enhance the Personal Data collected through our Digital Media with data we receive from outside records or third parties. For instance, we may combine purely demographic or survey information (e.g. age, gender, household information, and other interests, etc.) not linked to any Personal Data about you with Personal Data collected through our offers (such as during account registration).

– We may use the combined above-mentioned information and/or demographic information for our internal marketing and demographic studies and to constantly improve, personalize, and customize the products and services we provide you to better meet your needs. Some of the tools we use may involve automated individual decision-making subject to applicable law.

• Manage and track your inquiries and comments, including where relevant regarding compliance, via contact forms or contact email addresses: for the performance of a contract in particular.

• Display targeted ads about TAC’s products and services on the social media you are registered on and measuring ad performance. Subject to your consent, social media can also identify you through the cookies placed on our Digital Media. Once your data is shared on social media, it is used to enable such media, at your initiative, to find you among other users, and (i) to show you ads about our products and services when you browse the relevant social media, and (ii) to identify, based on your profile on the relevant social media (where you live, age, gender, language, socio-demographic characteristics, interests and behavior), lookalikes who may also be interested by TAC’s ads. Social media also provide us with reports on the results of our advertising campaigns (click-through rate, conversion rate, audience profile, etc.) to enable us to improve our future campaigns. In the context of these activities, we act as a joint controller together with each social media. We do not, however, collect or access at any time the Personal Data concerning you held by the social media concerned and relating in particular to your profile or your behavior on such social media. This type of Personal Data processing is based on our legitimate economic interest in offering relevant advertising content on social media, tailored to a specific audience.

We will ensure that your Personal Data remains accurate and up-to-date and avoid duplication in our database, by verifying each of your interactions with us and/or one of our affiliates to ensure your Personal Data is still accurate or needs to be completed or updated with the additional information you will have provided.

We may engage in automated profiling by monitoring your browsing activities on our Digital Media to better understand your preferences and centers of interests and adapt our marketing communications to your profile (see Section 2 above and our Cookie Policy).

TAC may process Personal Data involving automated decision making, including for the performance of a contract (e.g. avoid fraudulent payment).

If you choose not to submit any Personal Data when requested, you may not be able to participate in certain activities or take advantage of personalized features, and the Digital Media services and special services offered to you may be limited. For example, if you refuse to share your email address, you will not be able to receive our newsletters or otherwise register on our Digital Media. However, to simply browse our Digital Media and learn more about TAC and our products, you do not need to give us any Personal Data. In any event, we will always inform you of the Personal Data that is necessary in order to benefit from a service.

•  To affiliates within the Pernod Ricard Group

TAC may share your Personal Data within the Pernod Ricard Group, including its affiliates worldwide, for the purposes mentioned in Section 3.

• To third parties

TAC may also share your Personal Data with third parties, but only in the following circumstances:

– For marketing purposes, with our service providers, if you gave us your consent.

– For support purposes: We may use service providers, agents or contractors to provide support for the internal operations of our Digital Media and to assist us with administering them or the various features, programs and promotions available on it. Any such third party shall at all times provide the same levels of security for your Personal Data as TAC and, where required, are bound by a legal agreement to keep your Personal Data private, secure and to process it only on the specific instructions of TAC;

– For joint and co-sponsored programs and promotional purposes, with our partners and service providers: When we run a joint or co-sponsored program or promotion on our Digital Media with another company, organization, or other reputable third party; and, as part of this event, collect

and process Personal Data, we may share your Personal Data with our partner or sponsor, subject to your consent when required. If your Personal Data is being collected by (or is shared with) a company other than TAC as part of such promotion, we will let you know this at the time your Personal Data is collected;

– For targeted advertising purposes: we share your Personal Data with the following social media: Facebook and Instagram to display targeted ads on them about our products and services to you and people with a similar profile to you. In this context, the social media and TAC are acting as joint data controllers. We can provide you, on request, with a copy of the data processing agreements entered into with such social media. For more information about how such social media process your Personal Data and on how to exercise your rights with them in connection with any further processing of your Personal Data, we invite you to view their privacy policy on their website [Facebook and Instagram ].

– For litigation and safety purposes: We may also disclose your Personal Data if we are required to do so by law, or if in our good faith judgment, such action is reasonably necessary to comply with legal processes, to respond to any claims, or to protect the security or rights of TAC, its customers, or the public;

– In the event of a merger or acquisition of all or part of TAC by another company, or in the event that TAC were to sell or dispose of all or a part of the TAC business, the acquirer would have access to the information maintained by that TAC business, which could include Personal Data, subject to applicable law. Similarly, Personal Data may be transferred as part of a corporate reorganization, insolvency proceeding, or other similar event, if permitted by and done in accordance with applicable law.

TAC is a global company, and your Personal Data may be transferred across international borders to countries with a different level of data protection than the country from where you submitted your Personal Data. Your Personal Data may also be transferred between different companies of the Pernod Ricard Group located in different countries. TAC takes the appropriate measures to maintain security of the Personal Data both during transit and at the receiving location by implementing contractual clauses as set out by the European Commission, in accordance with applicable law.

Our main service providers for the operation of our Digital Media are based in the United States, as are our partners. Transfers of personal data to these service providers and partners are implemented in accordance with applicable laws and rely on standard contractual clauses as set out by the European Commission. Such service providers and partners, when acting as processors, are also bound by a contract that ensures a high standard of privacy protection and requires (amongst other provisions) that they act only on TAC’s instructions and implement all technical measures necessary on an ongoing basis to keep your Personal Data secure.

We will store the Personal Data that you sent us via our Digital Media in our databases as long as your account is active, for the duration of the contract with you or as needed to provide you the services you requested or to answer queries or resolve problems, or else to provide improved and new services. We may also retain your Personal Data in accordance with our internal retention procedure as

necessary to comply with our legal and regulatory obligations, resolve disputes and enforce our agreements.

We may thus retain your Personal Data after you stop using TAC’s services or our Digital Media according to the statute of limitations.

TAC takes all necessary technical and organizational measures to protect the confidentiality and security of your Personal Data collected via our Digital Media. These efforts include but are not necessarily limited to: (i) storing your Personal Data in secure operating environments to which the public does not have access, but only authorized TAC employees, and our agents and contractors; and, (ii) verifying the identities of registered users before they can access the Personal Data we maintain about them.

• If your Personal Data has been processed on the basis of your consent, you can withdraw your consent at any time, without impact on lawfulness of processing based on consent before its withdrawal.
• You can request access to your Personal Data.
• You can request the rectification of your Personal Data if it is inaccurate, incomplete or out of date.
• You can request the erasure of your Personal Data (i) if your Personal Data is no longer necessary for the purpose of the data processing, (ii) you have withdrawn your consent on the data processing based exclusively on such consent, (iii) you objected to the data processing, (iv) the Personal Data processing is unlawful, (v) the Personal Data must be erased to comply with a legal obligation applicable to TAC. TAC will take reasonable steps to inform the other entities of the Pernod Ricard Group of such erasure.
• You can request the restriction of the processing (i) in the event the accuracy of your Personal Data is contested to allow TAC to check such accuracy, (ii) if you wish to restrict your Personal Data rather than deleting it despite the fact that the processing is unlawful, (iii) if you wish TAC to keep your Personal Data because you need it for your defense in the context of legal claims (iv) if you have objected to the processing but TAC conducts verification to check whether it has legitimate grounds for such processing which may override your own rights if the data processing is based on the legitimate interest of TAC.
• You can request the portability of the Personal Data you provided to us, if the Personal Data processing is based on your consent or the performance of a contract and is carried out by automated means (i.e. excluding paper files).
• You always have the option not to share any of your Personal Data with us. If you choose this option, you may be limited in the activities and features we can provide you.
• You have the right to object to the processing of your Personal Data by us, at any time, for direct marketing purpose for the purposes of targeted advertising on social media or if the data processing is based on the legitimate interest of TAC (except if we can demonstrate compelling legitimate grounds for the processing).

Our Digital Media are 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 twenty years old to engage in activities and transactions on our Digital Media. If we are notified or learn that a Minor has submitted Personal Data to us through our Digital Media, we will delete such Personal Data.

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

The Absolut Company AB

S-117 97 Stockholm, Sweden

Visiting address: Marieviksgatan 19C S-117 43 Stockholm, Sweden

or sending an email to: privacy@absolut.com

You are informed that you can also lodge a complaint with the Supervisory Authority of the country where you are located if you have any concern about the conditions of processing of your Personal Data by Pernod Ricard.

In Sweden, you can contact the Swedish Data protection Authority (Integritetsskyddsmyndigheten) via their website at: imy.se.

We keep our Privacy Policy under regular review and we will place any updates on this web page.

This Privacy Policy was last updated in March 2024.