Privacy Policy

Pernod Ricard Brasil Privacy and Data Processing Policy

Updated June 27, 2023.

The purpose of this Privacy Policy is to demonstrate the commitment of

PERNOD RICARD BRAZIL INDUSTRY AND COMMERCE LTD., a Company duly constituted under the laws of Brazil, with administrative headquarters at Avenida Presidente Juscelino Kubitschek, 1,909, 16th floor – Vila Olímpia – CEP 04543-011, São Paulo/SP, in the City of São Paulo, State of São Paulo, CEP 35.702-383 (“Pernod Ricard”, “We” or “Our”), with the privacy and protection of your Data, in addition to establishing the rules on the Processing of your Personal Data, within the scope of the website’s services and functionalities:

  • https://www.amazzonigin.com/

including its subdomains, our mobile applications, our social media pages and any online formats to register for our events (“our digital channels”), in accordance with current laws, with transparency and clarity with You and to the market in general.

As a condition for accessing and using the exclusive features on our digital channels, You declare that you have read this Policy completely and carefully, being fully aware of its contents.

SPECIAL NOTE FOR CHILDREN AND ADOLESCENTS 

Please do not register on our digital channels if you are under 18 years of age.

Topics

  1. What Personal Data do we gather about you and how do we collect it?
  2. How and why do we use tracking technologies?
  3. For what purposes do we use your Personal Data?
  4. What happens if you do not want to provide your Personal Data?
  5. Who may we share your Personal Data with and why?
  6. Is your Personal Data sent to recipients located in other countries and why? 
  7. How long do we keep your Personal Data?
  8. How do we protect your Personal Data and what precautions should you take?
  9. What are your rights in relation to your Personal Data?
  10. How do we process children’s Personal Data?
  11. How can you contact us or the National Authority?
  12. Changes to our Privacy Policy
  13. Glossary
  1. What Personal Data do we gather about you and how do we collect it?

Data, including Personal Data, may be collected each time You interact or participate in any of the resources or services offered by our digital channels; only for the purposes set out in Clause 3 and the table below.

What do we collect? What do we collect for?
Registration data

Full name

  1. Identify and authenticate You.

  2. Comply with obligations arising from the use of our services.

  3. Notify You about the progress of your orders.

  4. Enable the delivery of products purchased by You.

  5. Enable you to contact us via Contact Us/Customer Service (SAC) to clarify doubts, suggestions and complaints.

  6. Manage your purchase history.

  7. Participation in promotions or events.

  8. Enable your reviews of Our products to be published on our digital channels.

  9. Expand our relationship, Inform You about news, features, content, news and other events that we consider relevant to You, when requested.

  10. Enrich your experience with us and promote our products and services.

  11. Guarantee the portability of Registration Data to another Controller in the same field of activity as us, if requested by You, complying with the obligation of article 18 of the General Personal Data Protection Law.

  12. Comply with legislation for issuing invoices for purchases you make with us and for making any necessary returns.

  13. Protect You by preventing fraud, protecting credit and associated risks, in addition to complying with legal and regulatory obligations.

NIN

E-mail

Date of birth

Gender identification

Country of Residence

Phone for contact

Delivery address

Marital status
Digital identification data and usage information

Source IP Address and Logical Port

  1. Identify and authenticate You.

  2. Solve technical problems.

  3. Maintain the protection and security of the website.

  4. Comply with legal record keeping obligations established by the Marco Civil da Internet – Law 12,965/2014.

  5. Restrict access to our Digital Media to comply with applicable law or contractual restrictions.

  6. Better understand how our Digital Media is used.

  7. Protect You by preventing fraud, protecting credit and associated risks, in addition to complying with legal and regulatory obligations.

Purposes for using cookies:

  1. To better understand how visitors use our Digital Media and the tools and services offered, and to improve their use and functionality.

  2. Allowing you to navigate between pages efficiently, remembering your preferences and generally improving your experience.

  3. Our Digital Media allows you to enjoy more uninterrupted visits and more accurately measures your behavior on our Site.

Device (OS version)

Geolocation

Timestamps every action You take

Which pages you accessed and when

What information about Our products have you accessed?

Selected language

Session ID

Cookies
Payment data

Credit card number and security code

  1. Comply with legal obligations and our contract when sharing Data with the third party company responsible for processing payment.

PIX key

The types and amount of information collected for the resources and services available on our digital channels may be updated and vary depending on Our activities.

You are solely responsible for the accuracy, veracity or lack thereof in relation to the Data you provide or for its outdatedness. Please be aware that it is your responsibility to ensure accuracy or keep them updated.

Likewise, We are not obliged to process or Process any of your Data if there are reasons to believe that such processing or Processing could result in us being in breach of any applicable law, or if you are using our digital channels for any illegal or unlawful purposes. or contrary to morality.

The Database formed through the collection of Data is our property and is under our responsibility, and its use, access and sharing, when necessary, will be done within the limits and purposes of the business described in this Policy.

The Database formed through the collection of Data is our property and is under our responsibility, and its use, access and sharing, when necessary, will be done within the limits and purposes of the business described in this Policy. We may also use demographic information about users of our digital channels, which we may obtain from third parties, such as Google or social media you use (“Usage Information”).

 

  1. How and why do we use tracking technologies?

Pernod Ricard uses tracking technologies, such as cookies, IP addresses or log files. Tracking technologies help us adapt our digital channels to your personal needs.

All technologies used will always comply with current legislation and the terms of this Privacy Policy.

  • Cookies: We use cookies and similar technologies (“cookies”) to better understand how visitors use our digital channels and the tools and services offered, and to improve their use and functionality. Cookies are small files that are placed on your device that serve a number of purposes, such as allowing you to navigate between pages efficiently, remembering your preferences and generally improving your experience. The use of cookies on our digital channels allows you to enjoy more uninterrupted visits and more accurately measures your behavior on our Site. You can find out more about the cookies we use and how to disable them at [Política de Cookies da Pernod Ricard], as it will be up to you to configure your Internet browser if you wish to block them and, in this case, some features we offer may be limited.
  • IP: An IP address is a number that is used by computers on the network to identify your computer every time you go online. We may monitor Internet Protocol (IP) addresses for (among other things): (i) resolve technical problems, (ii) maintain the protection and security of the website, (iii) restrict access to our digital channels to comply with applicable law or contractual restrictions, and, (iv) better understand how our digital channels are used;
  • Logs: We (or a third party on our behalf) may collect information in the form of log files that record activity on our digital channels and gather statistics about users’ browsing habits. These records are generated anonymously, and help us gather (among other things) (i) the type of navigation and operating systems of a user, (ii) information about a user’s session (such as the URL they came from, the date and time they visited our digital channels, which pages they viewed on our digital channels and for how long) and, (iii) other navigation data or click-stream similar. We also use information captured in the log file for our demographic and internal marketing studies so that we can constantly improve and customize the online services we provide. Log files are used for internal purposes only and are not associated with any particular user.

 

  1. For what purposes do we use your Personal Data?

In addition to the purposes listed in the table in Clause 1, we collect information about you to:

  • Respond to your service request: When you register or register on our digital channels (mobile app, websites, social media, etc.), your Personal Data is used to provide you with the relevant features and services that you have subscribed to, and offer you the benefits and privileges which are normally associated with your registration (e.g. receiving communications that you choose at the time of registration, being invited to events, participating in a competition, etc.);
  • When you purchase products on our websites: We use your Personal Data to manage your order and deliver your products. We may also implement technical solutions to detect fraudulent payment and guarantee payment for your purchases on our websites;
  • When you participate in any of our promotions, promotional campaigns and “buy and win”: We use your Personal Data, listed in the table in Clause 1, to comply with applicable legislation, as well as to manage your registration in one of our promotions, contact you during the action period, deliver products or gifts related to them, comply with the obligations arising from the promotional campaign, carry out the relevant security and anti-fraud validations to guarantee the veracity of the registration and compliance with the promotion rules, in accordance with the provisions of the Regulation and applicable legislation, adequately respond to your requests and queries, keep your registration updated for contact purposes by telephone, email, SMS, instant communication applications, direct mail, social media or other means of communication, protect rights and obligations related to the use of the platform (whatever the nature, such such as: websites, instant messaging applications, social media, etc.) as a means of proof in cases of illegal acts or acts contrary to the Privacy Policy, the relevant Regulations or any other legal document made available by Pernod Ricard, in case of undue changes to our systems and registrations or actions that may put the platform, the promotional campaign and its users at risk to, eventually, share the Data collected with the company responsible for managing and maintaining the platform, its products and services, as well as for managing the promotion and customer service;
  • Send you transactional communications and other notices relevant to you: For example, sending you a confirmation email when you register or unsubscribe from a specific subscription or activity, as well as certain service-related announcements (e.g., notices about updates to our privacy notices, discontinued features or programs in our digital channels, changes to our online services or technical support policies or other related changes);
  • Allow us to send you marketing information when you request: In addition to the purpose for which you submitted your Personal Data, you may also be given the option (by a check box or otherwise) to have your Personal Data used for an activity or service other than the primary activity or service for which you submit your Personal Data. you are requesting. For example, if you are registering for a contest or other promotion, you may also be invited to register fornewslettersor alerts from our digital channels that are sponsoring the promotion or from other websites. If you choose to receive these additional services, we use your Personal Data to provide it to you;
  • Because it is also in Pernod Ricard’s interest to better serve you: Subject to your authorization, where required, we may from time to time combine, update or otherwise enhance Personal Data collected through our digital channels with data we receive from external registries or third parties. For example, we may combine purely demographic or research information (e.g. age, gender, family information and other interests, etc.) not linked to any Personal Data about you collected through our offerings (such as during account registration).

We may use the above-mentioned combined 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 to you to better meet your needs. Some of the tools we use may involve automatic individual decision-making subject to applicable law.

We may determine your profile based on monitoring your browsing activities on our digital channels to better understand your preferences and center of interests and adapt our marketing communications to your profile, unless objections are made under the conditions described in Clause 9 of this Policy of Privacy.

Please note that the automatic tools used are regularly checked to ensure that Personal Data is processed fairly. Specific measures, such as data minimization, are implemented when creating profiles. We invite you to express your point of view using the right of access described above. You may also object to the outcome of the automatic decision by sending an email to the contact details contained in Clause 12 below.

 

  1. What happens if you do not want to provide your Personal Data?

If you choose not to submit any Personal Data when requested, you may not be able to participate in certain personalized activities and features, or the services of our digital channels and promotions 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 for our digital channels. However, to simply browse our digital channels and find out more about Pernod Ricard and our products, you do not need to provide any Personal Data. In any case, we will always inform you of the Personal Data that is necessary to benefit from a service and if you choose not to provide it, in particular the Registration Data mentioned in the table in Clause 1, we may be unable to provide all or part of our services. to you.

 

  1. Who may we share your Personal Data with and why?
  • Within the Pernod Ricard Group

Pernod Ricard may share your Personal Data within the Pernod Ricard Group, including its affiliates worldwide, for the purposes mentioned in Clause 3, always in compliance with the security and Data protection guidelines to meet the purposes of this Policy.

  • To third parties

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

  • For the purposes ofmarketing, if You request to receive communications from us.

  • For the purposes of suporte:We may use service providers, agents or contractors to provide support for the internal operations of our digital channels and to help us manage them or the various functions, programs and promotions available on them. Any third parties must always provide the same levels of security for your Personal Data as Pernod Ricard and, where required, are bound by a legal agreement to keep your Personal Data private, secure, and process it only in accordance with Pernod Ricard’s specific instructions. ;

  • For joint and co-sponsored programs and promotional purposes: When we run a joint or co-sponsored program or promotion on our digital channels 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, provided that it is duly authorized by You. If your Personal Data is being collected by (or is shared with) a company other than Pernod Ricard as part of this promotion, we will inform you about this when your Personal Data is collected;

  • For the purposes of legal proceedings and security: We may also disclose your Personal Data to competent judicial, administrative or governmental authorities, whenever there is a legal determination, request, request or court order, or if in its good faith judgment, such action is reasonably necessary to comply with legal processes, to respond to any claims, or to protect the safety or rights of Pernod Ricard, its customers or the public;

  • In case of incorporation or acquisition of all or part of Pernod Ricard by another company, or if Pernod Ricard has to sell or dispose of all or part of Pernod Ricard’s business, the acquirer would have access to information held by that Pernod Ricard business, which could include Personal Data, subject to applicable law. Likewise, Personal Data may be transferred as part of a corporate restructuring, insolvency proceeding or other similar event, if permitted and done in accordance with applicable law.

For the purposes of market intelligence research, disseminating data to the press and carrying out advertisements, the Data provided by You will be shared anonymously, that is, in a way that does not allow your identification.

 

  1. Is your Personal Data sent to recipients located in other countries and why?

Pernod Ricard is a global company and your Personal Data may be shared with companies outside the national territory. Pernod Ricard takes appropriate measures to maintain the security and protection of Personal Data when transferring it abroad in accordance with applicable legislation, by implementing standard contractual clauses as established by the European Commission and in accordance with applicable legislation.

Our main service providers for the operation of our digital channels are based abroad and they follow a contract that guarantees a high standard of data protection, following our instructions.

 

  1. How long do we keep your Personal Data?

We will store the Personal Data you send to us via our digital channels in our databases for as long as your account is active, for the duration of the contract we have entered into with you or as necessary to provide you with requested services or to respond to inquiries or solve problems, provide improved or new services.

Therefore, the Personal Data collected and activity records will be stored in a secure and controlled environment for a minimum period that generally follows the table below:

STORAGE PERIOD LEGAL BASIS
Registration data

5 years after the end of the relationship

Articles 12 and 34 of the Consumer Protection Code
Digital identification data

6 months

Art. 15, Civil Rights Framework for the Internet
Other data

As long as the relationship lasts and there is no request for deletion or revocation of consent

Art. 9, Section II of the General Personal Data Protection Law 

We may also retain your Personal Data in accordance with our internal retention procedure, for the purposes of auditing, executing our agreements, security, fraud control and credit protection, in which case we may retain the record history of your Data for a longer period of time. in the cases that the law or regulatory norm so establishes or to preserve rights.

 

  1. How do we protect your Personal Data and what precautions should you take?

Pernod Ricard takes all technical and organizational measures to protect the confidentiality and security of your Personal Data collected through our digital channels, including confidential information. These efforts include, but are not necessarily limited to: (i) store your Personal Data in secure operating environments that are not publicly available and that are only accessible to authorized Pernod Ricard employees, our agents and contractors; It is, (ii) verify the identities of registered users before they can access the Personal Data we maintain, respecting the principles of proportionality, necessity and relevance to our business objectives.

However, You are also responsible for the confidentiality of your Personal Data and must always be aware that sharing passwords and access data violates this Policy and may compromise the security of your Data and our digital channels.

It is very important that You protect your Data against unauthorized access to your computer, account or password, in addition to making sure to always click “exit” when ending your browsing on a shared computer. It is also very important that You know that we will never send electronic messages requesting confirmation of data or with attachments that can be executed (extensions: .exe, .com, among others) or evenlinks for eventual downloads.

All payment transactions, whether credit card or not, are executed using SSL technology(secure socket layer), ensuring that all your Data, such as: delivery address, credit card details and order history, are not unlawfully disclosed. Furthermore, this technology aims to prevent information from being transmitted or accessed by third parties.

When You use our digital channels, You may be directed, via link, to other portals or platforms, which may collect your information and have their own Data Processing Policy. It is up to you to read the Privacy and Data Processing Policies of such portals or platforms outside of our environment, and it is your responsibility to accept or reject it. We are not responsible for the Privacy and Data Processing Policies of third parties nor for the content of any websites or services linked to environments other than ours.

 

  1. What are your rights in relation to your Personal Data?

You can request our Personal Data Officer by email Pernod Ricard Brasil Privacy Channel the exercise of your rights, such as:

  • If your Personal Data has been processed with your consent, This consent can be withdrawn at any time. However, if You withdraw your consent for purposes that are fundamental to the regular operation of our digital channels and services, such environments and services may become unavailable to You.

  • You can ask to access your Personal Data.

  • You can ask for rectify your Personal Data if these are incorrect, incomplete or out of date.

  • You may request that your Personal Data collected by Us be erased (i) if they are no longer necessary to achieve the purposes for which they were collected, (ii) if you have withdrawn your consent to data processing based solely on that consent, (iii) if you objected to Data Processing, (iv) if the processing of Personal Data is unlawful, (v) if the Personal Data must be deleted to comply with a legal obligation applicable to Pernod Ricard. Pernod Ricard will take the necessary steps to inform other Pernod Ricard group entities of this deletion.

  • You can ask restriction/limitation of processing.

  • You can ask for the portabilityof the Personal Data provided to us.

You always have the option not to share your Personal Data with us. If you choose this option, you may limit the activities and resources we can provide to you.

You have the right to object to your Personal Data being processed by us, including for profile-based marketing purposes.

If You request the deletion of your Personal Data, it may occur that the Data needs to be kept for a period longer than the deletion request, in accordance with article 16 of the General Personal Data Protection Law, to (i) compliance with legal or regulatory obligations, (ii) study by a research body, and (iii) transfer to a third party (respecting the data processing requirements set out in the same Law). In all cases through the anonymization of Personal Data, as long as possible.

After the maintenance period and legal necessity have expired, Personal Data will be deleted using secure disposal methods, or used in an anonymized form for statistical purposes.

 

  1. How do we process children’s Personal Data?

Our Site is not intended for children under the legal drinking age (“Minors”), therefore we do not knowingly collect Personal Data from Minors. You must be at least 18 (eighteen) years old to create an account and participate in activities and transactions on our digital channels. If we are notified or become aware that a Minor has submitted Personal Data to us through our digital channels, we will delete such Personal Data.

 

  1. How can you contact us or the National Authority?

If you have any questions, complaints or comments regarding this Privacy Policy or our data processing practices, please contact us at Pernod Ricard Brasil Privacy Channel

You are hereby informed that you can also lodge a complaint with the Supervisory Authority of the country in which you are located, if you are concerned about the conditions in which your Personal Data is processed by Pernod Ricard.

 

  1. Changes to our Privacy Policy

You acknowledge our right to change the content of this Policy at any time, according to the purpose or need, such as for adequacy and legal compliance with a provision of law or standard that has equivalent legal force, and it is up to You to check it whenever you carry out the access our digital channels or use our services.

If updates to this document occur and require new collection of consent, You will be notified through the contact channels that You provide.

If any point of this Policy is considered inapplicable by a Data Authority or court, the other conditions will remain in full force and effect.

You acknowledge that all communication carried out by email (to the addresses provided in your registration), SMS, instant communication applications or any other digital form, are also valid, effective and sufficient for the dissemination of any matter that refers to the services that we provide, to your Data, as well as the conditions of its provision or any other matter addressed therein, with exceptions being only what this Policy provides as such.

This Policy will be interpreted in accordance with Brazilian legislation, in the Portuguese language, with the forum of your domicile being chosen to resolve any dispute involving this document, unless there is a specific exception regarding personal, territorial or functional jurisdiction under the applicable legislation. If you are not domiciled in Brazil, you submit to Brazilian legislation, agreeing, therefore, that in the event of a dispute to be resolved, the action must be filed in the São Paulo/SP District Court.

 

  1. Glossary

For the purposes of this Policy, the following definitions and descriptions must be considered for your better understanding:

  1. Data: Any information entered, processed or transmitted through our digital channels.

  2. Personal data: Data related to an identified or identifiable natural person.

  3. Anonymization: Use of reasonable technical means available at the time of Processing, through which data loses the possibility of association, directly or indirectly, with an individual.

  4. In charge (Data Protection Officer -DPO): Person appointed by Us to act as a communication channel between the controller, data subjects and the National Data Protection Authority (ANPD).

  5. Access Account: Credential required to use or access the exclusive features of our digital channels.

  6. Cookies: Small files sent through our digital channels, saved on your devices, which store preferences and little other information, with the purpose of personalizing your browsing according to your profile.

  7. IP: Short forInternet Protocol. It is the alphanumeric set that identifies users’ devices on the Internet;

  8. Logs: Activity records of any users who use our digital channels.

  9. Session ID: Identification of the user session when accessing our digital channels.

  10. Uniquely automated decisions: These are decisions that affect a user that have been programmed to work automatically, without the need for human operation, based on automated Processing of Personal Data.

  11. Treatment: Any operation carried out with Personal Data, such as those relating to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer , diffusion or extraction

 

This Privacy Policy was last updated on July 7, 2023