Privacy Policy

Le Cercle Saint-Barthélemy Privacy Policy

We take your privacy very seriously and we respect your right to privacy when you use this website (the "Website"). The Privacy Policy, together with our Cookies Policy, which can be found here, set out the basis on which we collect, store, use and process the personal data (“Personal Data”) you share with us through our Website.

"We", "us" and "our" refer to Pernod Ricard Americas Travel Retail LLC d/b/a Pernod Ricard Caribbean and Central America a corporation duly organized under the laws of the State of Delaware, United States of America, with its registered address at 400 Waterford Way, Suite 800, Miami FL 33126 (“Pernod Ricard”).

We collect, and process Personal Data about you for the purposes set out in section 4 below. We are the data controller when processing your Personal Data in the conditions described in this Privacy Policy, which includes any Personal Data you submit to this Website.

Please read this Privacy Policy carefully as it contains important information on who we are and how and why we collect, store, use and share your Personal Data. It also explains your rights in relation to your Personal Data and how to contact us or supervisory authorities in the event you have a complaint.

What Personal Data do we collect about you and how?

We collect Personal Data, that you provide to us, such as by filling out a contact form, registering for an account, using interactive features, subscribing to a service, participating in a marketing promotion, ordering a product or a service, requesting information and/or material or complete surveys. Personal Data means any information that can be used to personally identify you or contact you online or elsewhere.

We may collect and use the following Personal Data about you:

your name and contact information, including postal address, email address and telephone numbers and, if applicable, business contact details;
information to enable us to check and verify your identity, e.g. your date of birth;
your gender information, if you choose to give this to us;
your billing and delivery information, transaction and payment card information;
your contact history, purchase history and saved items;
information about how you use our Website;
your responses to surveys, and promotions;
your IP address and your mobile/tablet/device ID;
customer service information (e.g. customer service inquiries, comments);
content you may provide to us (e.g. pictures, comments etc.).

This Personal Data is required for fulfilling the purposes set out in section 3 below. If you do not provide the Personal Data we ask for, it may delay or prevent us from providing products or services to you.

How do we collect your Personal Data?

We collect most of the Personal Data directly from you—in person, by telephone, text message, email and/or via our Website. This usually occurs when you order one of our products or take part in one of our promotional activities, for example:

Registration or sign-up online: e.g. Websites or subscribing to our newsletter or creating an account on our Website;
Joining a loyalty program or subscribing to a newsletter;
Buying products or services online;
When doing e-commerce on our Website;
Attending any of our experience courses or events;
Tastings;
Feedback, questions, enquiries, surveys or comments through 'Contact us' or
Any other request that requires the submission of Personal Data.

The type and amount of information we collect for the features listed above will vary and depends on the activity.

We may also collect Personal Data from cookies on our Website (see below - How and why do we use tracking technologies?).

Subject to applicable laws, we may use a variety of technologies that collect and provide information about how our Website is accessed and used by you. We may also use demographic information about who uses our Website, which we get from third parties such as Matomo, a web analytics platform (we call this "Usage Information"). Usage Information may consist of the pages you have visited and for how long you stayed on the page, the session duration and which beverage information (or other content) you accessed or provided. It also includes which language you use, demographic information about you (such as your age, gender and interest areas, where available), technical information about your device (such as its OS version, the browser used, browser’s language) and which pages you have visited before you visited the current page.

We collect this information to gain a better idea of how people interact with our websites so we can then tailor and improve them accordingly. Most Usage Information that we collect can't be linked to you individually, but if we can link it to you, then we treat it in accordance with this Privacy Policy.

How and why do we use tracking technologies?
We use tracking technologies such as cookies, IP address recording or log files, to gather technical information such as your web browser type and which operating system you use, the webpage you came from, your path through our Website and your Internet Service Provider. This is so we can improve the functionality of our Website and better understand how visitors like you use our Website and the tools they offer.
Often, individuals will interact with us in multiple ways and will provide us with personal information in different contexts. We may use your personal information to obtain a profile of your different interactions with us and to understand your preferences.
These tracking technologies help us tailor our Website and services to your personal needs:
- Subject to your consent where required by applicable law, our Website use cookies and similar technologies ("cookies"). Cookies are small files placed on your device which serve a number of purposes, such as remembering your preferences. You can learn more about which cookies we use and how to disable them in our Cookies Policy;
- An IP address is a number used on a network to identify your computer every time you connect to the Internet. We may keep track of Internet Protocol (IP) addresses to (among other things): (i) troubleshoot technical issues, (ii) maintain website safety and security, (iii) track location and behaviour, and (iv) better understand how our Website is utilised e.g. using Matomo;
- We (or a third-party on our behalf) may collect and use your computer or mobile/tablet device ID to provide a more tailored browsing experience, to alert you to nearby events or promotions and for reporting and analysis;
- We (or a third-party on our behalf) may collect information in the form of logs files that record activity and gather statistics about browsing habits. These entries are generated anonymously and help us gather (among other things): (i) your web browser type and operating system, (ii) information about your session (such as the URL you came from, the date and time you visited our Website, and which pages you have viewed and for how long), and (iii) other similar navigational or click-stream data. We also use log file information for our internal marketing and demographic studies, so we can constantly improve and customise the online services we offer you. Log files are only used internally and are not associated with any personally identifiable individual.
For what purpose do we use your Personal Data and based on which legal basis?

The purposes for which your Personal Data may be processed are described in the chart below, with the corresponding legal bases:

Legal basis of the processing	Purposes of the processing
Performance of a contract (the terms of use of our Website or a sales)	· When you register or sign-up an account via our Website: The Personal Data you give is used to provide you with the benefits that typically come along with registration. · When ordering a product on our Website: (i) we (or a third party on our behalf) will use your Personal Data to create your account, facilitate the purchase process, manage your order and deliver your products under the contract you have with us (or the third party) and to understand your purchase history. · We may also use your email address to send you transactional or administrative communications such as confirmation emails when you sign up for, or unsubscribe from, a specific registration or activity. · We may also use it for certain service-related announcements, such as updates to our Privacy Policy, discontinued features or products on our Website, changes to our online services or technical support policies.
Pernod Ricard legitimate interest to better serve your needs	· Processing relating to the use of your contact details to send you information on the products and brands that you have signed up to (by email, text message, telephone or post). We have a legitimate interest in processing your Personal Data for promotional purposes for communications sent to you as an existing customer on products similar to those we have already provided to you). · Processing relating to the conduct of surveys and market search · Management of invitation to events and management of attendance to events · We may use your Personal Data (i) to create your client profile, (ii) to recommend products and experiences based on your personal interests, (iii) to create personalized estimates with products and experiences and send them to you via email, WhatsApp and on the Website ; · Manage feedback, questions, or comments through our 'Contact Us' form. If you contact us via an online contact form, your information is used to respond to your inquiry or comment. · Preventing and detecting fraud and/or criminal activity that could be damaging for us and for you; · Protecting our commercially valuable information and also our intellectual property; · For credit control purposes and to make sure our customers can pay for the products we provide; · Understanding how our business is performing and considering how to improve our performance; and · Ensuring we are able to keep up to date with our customers and contacts and developments in their organisations.
Consent	· Sending you communications about other Pernod Ricard products including exclusive offers, promotions or new products (by email, text message, telephone or post).

What happens if you do not wish to share your Personal Data with us?

If you choose not to submit any Personal Data when requested, you may not be able to participate in certain activities or use some of the personalised features of our Website. This may also limit the services and special offers we can provide you. For example, if you refuse to share your email address, you will not be able to receive any of our newsletters or otherwise register in our Website. However, you do not need to give us any Personal Data to simply browse our Website and learn more about us and our products.

Who do we disclose your Personal Data to and why?

We will never share your Personal Data with any third party that intends to use it for direct marketing purposes unless we have specifically told you and you have given us explicit consent to do this.

We may share your Personal Data with internal personnel of Pernod Ricard on a need-to-know basis.

We may disclose your Personal Data to the following recipients or categories of recipients acting on our behalf and/or as partners (processors), limited to the purpose of the execution of their obligations, which are contractually bound to adhere to an adequate level of data protection when processing your personal data:

We may share your Personal Data with Pernod Ricard SA, 5 cour Paul Ricard, 75008 Paris, France;
We may use third parties to help deliver our products to you, such as our retailer partner managing orders and deliveries, payment service providers, warehouses and delivery companies, external client services;
We may use service providers, agents or contractors such as marketing and digital agencies to support the internal operation of our Website, and to assist us with administering them or the various functions, programs and promotions available on It. Any such third party must provide appropriate levels of security for your Personal Data and, where required, are bound by a legal agreement to keep your Personal Data private, secure and to process it only on our specific instructions;

We may also disclose your Personal Data if we are required to do so by law or by law enforcement agencies or regulatory bodies, or if such action is necessary to comply with legal or regulatory processes, to respond to or pursue any claims, or to protect the safety or rights of us, our employees, customers, or the public;

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

We may share aggregated demographic or survey information with third parties, but this information is in anonymous form and does not contain any Personal Data. The aggregate information that we share may include anonymous information that is captured through the use of cookies and other similar tracking technology, as explained in Articles 2 and 3.

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

Your Personal Data may be transferred across international borders to countries that have different data protection laws to the country from where you submitted your Personal Data.

We will, however, ensure the transfer complies with data protection law both during transit and at the storage location and all Personal Data will be secure. Our standard practice is to use standard data protection contract clauses (i.e. standard contractual clauses) that have been approved by the European Commission.

How long do we keep your Personal Data?

We may store the Personal Data that you send to us via our Website in our databases. We will not retain your Personal Data for longer than necessary for the purposes set out in this Privacy Policy.

Different retention periods apply, depending on the purposes of the processing concerned:

Purpose of the processing	Data retention periods
Creation of accounts, Management of orders, provision of products	If a product is ordered: duration of the contractual relationship If an account is created but no product is ordered: 3 years after the last sign-in
Management of feedback, questions and claims	Duration of the contractual relationship
Marketing activities, including: (i) Sending emails on the products and brands that you have signed up to (ii) Sending emails on other Pernod Ricard products (iii) Conducting surveys and market search (iv) Inviting customers to our events	(i) 3 years after the last contact from customer (unless customer opts-out before) (ii) 3 years after the last contact from customer (unless customer withdraws consent before) (iii) Until the objective of the survey/market search is satisfied (unless customer opts-out before) (iv) Until the objective of the event is satisfied (unless customer opts-out before)
Analysis of Usage Information	Please refer to our Cookies Policy.

We may also need to retain your Personal Data to comply with our legal and regulatory obligations, resolve disputes, enforce our agreements, and similar records management purposes.

Once the retention period is expired, your Personal Data will be deleted from all systems.

If you ask us to delete your information in accordance with your rights set out in Article 10 below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future.

How do we keep your Personal Data secure?

We have appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed unlawfully. These include: (i) storing your Personal Data in secure operating environments that are not available to the public and that are only accessible to authorised employees, our agents and contractors; and, (ii) verifying the identities of registered users before they can access Personal Data we store about them.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Your rights

You have the following rights, which you can exercise free of charge:

You can ask us to:

provide a copy of your Personal Data (i.e. the right of access);
correct any mistakes in your Personal Data;
delete your Personal Data—in certain situations;
restrict processing of your Personal Data—in certain circumstances, e.g. if you contest the accuracy of your Personal Data;
provide you with a copy of the Personal Data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.

You can object:

at any time to your Personal Data being processed for direct marketing including profiling;
in certain other situations to our continued processing of your Personal Data, e.g. processing carried out for the purpose of our legitimate interests.

If your Personal Data has been processed on the basis of your consent, you can withdraw your consent at any time. We hope that we can resolve any query or concern you may raise about our use of your information.

You can also define instructions for the retention, deletion and disclosure of your Personal Data after your death (please note these instructions can be general or specific).

If you have any concern about the processing of your Personal Data by Pernod Ricard, you also have the right to complain to the French Data Protection Authority (i.e. the “CNIL”): https://www.cnil.fr/.

If you would like to exercise your right to object to direct marketing or any of your other rights, please contact us by sending an email to: CCA.DataPrivacy@Pernod-Ricard.com

Your objection (or withdrawal of consent) may mean we cannot provide the products or services you have requested of us or you may not be able to use the services we offer. We will advise you where this is the case. In certain circumstances even if you withdraw your consent, we may still be able to process your Personal Data if required or permitted by law or for the purpose of exercising or defending our legal rights or meeting our legal and regulatory obligations.

If you participated in a program that involved a third-party and you agreed to receive communications from that third party, you will need to contact them directly to opt-out. This process should be outlined in the third-party's privacy policy.

How do we treat children's information?

Our Website is not intended for children under the age of majority ("Minor"), so we do not knowingly collect Personal Data from Minors. You must be at least eighteen years old (or, if the legal age to buy or drink alcohol where you live is higher, you must be at least that age) to create an account and engage in activities and transactions on our Website. By creating an account or engaging in activities or transactions, you confirm that you are at least eighteen years old (or, if the legal age to buy or drink alcohol where you live is higher, that you are at least of that age) and are fully able to enter into, comply with and be legally bound by our terms of use made available to you and this Privacy Policy. If we are notified or learn that a Minor has submitted Personal Data to us through our Website, we will delete their Personal Data.

Do we link to other third-party websites?

Our Website 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 that may use our brands or logo(s) as part of a co-branding agreement.

The operators of other sites may collect information from you which will be used by them in accordance with their own data protection policy or privacy policy. We have no control over these third parties, and your use of their websites and features are subject to the privacy policies posted on those websites. We are not responsible or liable for the privacy practices or business practices of any third-party website. Therefore, you should exercise caution and review the privacy policies applicable to those external websites you visit before providing your Personal Data.

How can you contact us?

If you have any questions, complaints, or comments about this Privacy Policy or our how we collect and manage your Personal Data, please contact us by sending an email to: CCA.DataPrivacy@Pernod-Ricard.com

Changes to this Privacy Policy

This Privacy Policy was last updated on December 14, 2022. We may change this Privacy Policy from time to time, so please check back regularly to keep informed of updates to this Privacy Policy and our Cookies Policy.