Privacy Policy

Patrón Spirits International AG
Quaistrasse 11
8200 Schaffhausen
Switzerland

PRIVACY POLICY

This privacy policy (the “Privacy Policy”) sets forth a description of practices related to personal data privacy and security of Patrón Spirits International AG and its successors, parents, subsidiaries, affiliates and related companies or other companies under common control that we have now or in the future operate (the “Company,” “we,” “our,” or “us”). The singular term “Website” includes all websites and all devices or applications that collect personal information from you that we have now or in the future operate that link to this Privacy Policy, web pages within each such website, device or application, any equivalent, mirror, replacement, substitute, or backup website, device, or application and web pages that are associated with each such website, device, or application. By accessing the Website and providing us with personal information, you acknowledge the applicability of this Privacy Policy.

In addition to this Privacy Policy, we have established Terms and Conditions that set forth the general rules and policies governing your use of the Website. A copy of the Terms and Conditions can be found at http://www.patrontequila.com/terms.html.

The Company is committed to protecting your personal data. We provide this Privacy Policy to explain the type of information we collect on the Website and how that information is used.

Please note: The laws and regulations in different countries impose different (and even conflicting) requirements on the Internet and data protection. The servers that make the Website available worldwide are located in the USA. Please note that any information you provide will be transferred to the USA, as further described below.

By using the Website and/or providing us your personal information, you signify your acknowledgement of this Privacy Policy. If any term in this Privacy Policy is unacceptable to you, do not provide us your personal information or use the Website.

I. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

Access to Website

You may access and use the Website and the services available on the Website only if you are at least the minimum legal age to purchase alcoholic beverages in the jurisdiction in which you are located. In order to confirm that you are of legal age, you will provide us with your date of birth and country of residence. We do not knowingly collect any further information from individuals who are under the minimum legal age in their countries of residence. If you believe we might have any information from or about a child under the age of 16, please contact the data controller (contact information provided below).

Registration Information

When you register with the Website, you can elect to provide us with your personal information (first name, last name, email address, zip code, birthday (month/day/year), and whether you are a tequila lover or a bartender) to receive information and updates on our products and services, as well as those of our subsidiaries, affiliates, and parent companies and any of their related businesses, as well as those of our third-party partners. We use your return email address to answer the email that we receive, and we may use your return email address to send you other information. Such addresses are not used for any other purpose.

Polling Answers

When visiting the Website, you may be asked questions, the answers to which are collected on an aggregate basis (i.e., the answers will not be stored in a manner that identifies them with you personally).

Contest and Sweepstakes

Registration may be required to be eligible to enter online contests or sweepstakes. The Company uses the information you provide when registering to manage your entry; fulfill prizes (and disclose your information to third-party entities that assist with such fulfillment); and, for other marketing and promotional purposes related to the contests or sweepstakes as disclosed on the rules applicable to a particular contest or sweepstakes.

IP Addresses

In addition to information that you provide us voluntarily, the Company collects aggregate information in the form of IP addresses. An IP address is a number that is automatically assigned to your computer whenever you are surfing the Web. Web servers are the computers that “serve up” web pages and automatically identify your computer by its IP address. When you request a page from the Website, our servers log your IP address and certain other information, such as browser type, internet service provider (ISP), referring/exit pages, network information, hardware type, location, domain host, referring URL, operating system, data/time stamp, and clickstream data. We do not link this automatically collected data to any other personal data we hold about you.

Cookies and Other Tracking Devices

The Company uses cookies on the Website. Cookies are small text files that are stored on the hard drive of your computer or on your mobile device when you visit our website. Cookies include information such as language preferences, so that such information does not have to be re-entered when visiting the website again. Some cookies ensure that the graphics of the website are displayed correctly, and other cookies ensure that the Website runs smoothly. We use cookies to make your future activities go faster or to enhance your experience on the Website by recalling information that you already made available to us.

Some of our business partners also use such data to provide us with aggregated data and information in an anonymous form regarding the use of our Website.

We use cookies to:

• track, report, retarget (i.e., behavioral ad retargeting/remarketing), and communicate with users who opt-in to email communications;
• personalize our site/application (or “app”) to you. For example, to try to ensure that language and region displays are correctly configured for you;
• improve our site/app. For example, knowing how our users navigate our site/app and use its features allows us to streamline the user experience, speed up searches, identify bugs, make enhancements and, ultimately, get you to the right page and product faster;
• estimate our audience size and usage pattern;
• collect -aggregated information in an anonymous form about the websites from which users have travelled to our site/app;
• store information about any preferences that you set, so we can do things like greet you personally and speed up your log-in when you come back to our site/app; and
• identify which of your device(s) you use to access our site/app or any account that you have registered on it.

The cookies we use:

• may persist on your device between visits to our site/app, so that, for example, we can identify you when you visit again; and
• may be provided either by us or by third-party service providers (such as analytics and search engine providers).

If you don’t want the Website to store cookies on your computer, you can use the opt-out tools provided below or adjust the corresponding browser settings (please also see Section V regarding disclaimers):

• Internet Explorer: http://windows.microsoft.com/en-US/windows-vista/How-to-manage-cookies-in-Internet-Explorer-9
• Chrome: http://support.google.com/chrome/bin/answer.py?hl=en-GB&hlrm=nl&answer=95647
• Firefox: http://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences?s=cookies&r=5&as=s
• Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac

When you deactivate cookies, please note that some graphics may not be displayed correctly or that you may not be able to use some applications. Below you will find a detailed list of the first-party and third-party cookies that we could use on our Website:

FIRST-PARTY COOKIES
Name of cookie	Purpose	Amount of Time Stored	More Information and Opt-out
psc-login	Track a logged in user	30 days	N/A
pt-accept-cookie	Track whether a user has accepted the cookie banner	30 days	N/A
pt-auth	Track info acquired at age gate	Session or 30 days	N/A
pt-birthday	Track info acquired at age gate	30 days	N/A
pt-bot-tender	Hide Bot-Tender throughout the site	1 day	N/A
pt-moty-cookie	MOTY vote tracking	365 days	N/A
pt-moty-last-vote-date	MOTY vote tracking	365 days	N/A
pt-moty-last-vote-for	MOTY vote tracking	365 days	N/A
pt-moty-last-vote-timezone	MOTY vote tracking	365 days	N/A
pt-popup-shown	Track whether a user has seen the site popup	365 days	N/A
pt-rule	Track the last homepage hero a user has seen (used for multiple heroes)	30 days	N/A

 

FIRST-PARTY COOKIES
Name of cookie	Purpose	Amount of Time Stored	More Information and Opt-out
Google Analytics	They are used to anonymously monitor how the visitor uses the Website for statistical purposes, allowing Company to optimize how the Website works and offer a better browsing experience.	60 days	We have implemented Google Analytics features that use Display Advertising information for Google Analytics Demographics and Interest Reporting. You can opt-out of Google Analytics for Display Advertising by going to the Google Analytics opt-out page or by visiting https://www.google.com/settings/ads/.
DoubleClick	They are used to select online advertising messages based on the visitor’s interests, based on the information collected during browsing, and to prevent the visitor from viewing ads already displayed in the past.	Permanent	For more information and to opt-out click on https://www.google.com/settings/ads/.
Optimizely	Optimizely helps us improve our Website via A/B testing. Optimizely leverages first-party cookies to bucket visitors into different UX variations and track and report on test performance.	180 days (from setup)	For more information about Optimizely, please visit: https://www.optimizely.com/privacy. Here’s how you can opt out of Optimizely’s cookie: https://www.optimizely.com/opt_out.

 

II. HOW WE USE AND SHARE THE INFORMATION COLLECTED

The processed personal information is limited to the data that is necessary for carrying out the purpose for which such personal information is collected. We use information collected from you in the following ways:

• We use information collected for internal user activity and marketing analysis, for example, to assess trends amongst our consumers or to measure the amount of traffic to the Website, based on our legitimate interest in improving our marketing analysis and promoting the Company’s position in the market. We also share non-personal information with others, such as advertisers, in an aggregated, anonymous form, which means that the information will not contain any personally identifiable information about you. [1]Please also see Section V regarding disclaimers.
• We use your personal information in order to communicate with you about our products and services and those of our subsidiaries, affiliates, and parent companies and any of their related businesses, and those of our third-party partners, including in the context of the Wireless Marketing Services described below, based on our legitimate interest in communicating with our customers about their requests or, where required, based on your specific consent.
• We arrange for selected companies who provide services such as marketing and promotion to send you information that may be of interest to you if you have elected to receive such information, based on your specific consent. In such circumstances, your personal information will be disclosed to these organizations who will agree to be bound by the terms of this Privacy Policy. We will obtain your permission (e.g., opt-in consent) before we send you any such communications.
• Information that you post on or through the public areas of the Website (e.g., chat rooms, bulletin boards, and discussion groups) are generally accessible to, and may be collected and used by, others and may result in unsolicited messages or other contact from others. Users of the Website are encouraged to exercise caution when providing personal information about themselves in public or interactive areas.
• In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personally identifiable information that you provide and other information concerning your relationship with us.
• We only transfer your personal information to third parties under confidentiality obligations for the performance of services provided to us, including third-party providers of services related to the operation and management of the Website, or in connection with the administration and support of the activities noted above (e.g., the administration of a marketing campaign). Third-party providers of services will only receive personal data according to the purposes of the service agreement concluded with us.
• We may disclose your personal information if permitted by law or required to do so by law or where we believe such action is necessary in order to protect or defend our interests or the interests of our customers or users of the Website.

Your personal data will be processed based on our legitimate business interests described above and only as long as our legitimate interests are not overridden by your interests or fundamental rights and freedoms or if you have given your consent to a specific data processing activity, as set out above. The Company ensures that its internal governance procedures specify the reasons behind decisions to use personal information for alternative processing purposes. Prior to using personal information for a purpose other than the one for which it was initially collected, data subjects will be informed about such a new purpose.

We have put in place all appropriate physical, electronic, and managerial procedures to safeguard the personal data and other type of information we collect. We have implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk, with such risk analysis including an analysis of the risk compromising the rights of a data subject, costs of implementation, and the nature, scope, context and purposes for data processing.

The measures include:

• encryption of personal data where applicable/appropriate;
• the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
• the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident; and
• a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

The Company will only grant access to your personal data to the following categories of recipients:

(i) subsidiaries, affiliates and related companies or other companies under common control that we have now or in the future operate; (ii) service providers (for example, the website service provider); and (iii) marketing agencies who carry out marketing on behalf of the Company with your consent. The Company will only grant access to your personal data on a need-to-know basis, and such access will be limited to the personal data that is necessary to perform the function for which such access is granted.

III. YOUR RIGHTS AS A EUROPEAN DATA SUBJECT WITH REGARD TO YOUR PERSONAL DATA

If your personal data is collected within the European Union, you may at any time exercise certain rights you may have under applicable law and regulations, including the following rights:

• The right to request access to your personal data, which includes the right to obtain confirmation from us as to whether or not personal data concerning you is being processed, and where that is the case, access to the personal data and information related to how it is processed.
• The right to rectification or erasure (“right to be forgotten”) of your personal data, which includes the right to have incomplete personal data completed, including by means of providing a supplementary statement, and certain rights to request that we erase your personal data without undue delay.
• The right to restrict or object to processing your personal data, which includes restricting us from continuing to process your personal data under certain circumstances (e.g., where you contest the accuracy of your personal data, where the processing is unlawful, where your personal data is no longer needed for the purposes of processing, or where you have otherwise objected to processing related to automated individual decision-making).
• The right to data portability, which includes certain rights to have your personal data transmitted from us to another data controller.
• Where data processing is based on your consent, you have the right to withdraw consent at any time.
• The right to lodge a complaint with a supervisory authority.
• In some countries, the right to give us instructions about how to handle your personal data in the event of your death.

Any requests related to the above rights may be made by filling out our Form or sending an email to privacy@patronspirits.com.

Data collected based on our legitimate business interests will be retained for as long as permitted by law. Any first-party cookies used will be erased after thirteen (13) months, unless your consent is renewed.

Unless otherwise required by law, the Company will, in any event, erase personal data when it is no longer necessary in relation to the purposes for which was collected or otherwise processed; when you withdraw your consent (where lawfulness of processing was based on your consent) and there is no other legal ground for the processing; when you object to the processing and there are no overriding legitimate grounds for the processing; when your personal data has been unlawfully processed; and when it is necessary to comply with legal obligations.

IV. WIRELESS MARKETING SERVICES

We may provide you with the opportunity to register for special promotions, services, news, programming and information delivered via text messaging and other wireless devices (e.g., SMS), such as mobile phones (the “Mobile Services”) and, in the event we do so, users are required to provide separate consent to receive such information, either by registering on the Website or via their wireless device (or both). We may require you to consent again in a subsequent confirmation message. Such services and promotional opportunities may be provided by our third-party affiliates and service providers.

We will only use information you provide in connection with the Mobile Services to transmit your text message(s) or as otherwise described in this Privacy Policy and the Terms and Conditions, unless we provide advance notice of any other use. Nonetheless, we reserve the right at all times to disclose any information as necessary to satisfy any law, regulation or governmental request, to avoid liability, or to protect our rights or property.

V. THIRD-PARTY WEBSITES

The Website and Privacy Policy may contain links or references to other websites that are outside of our control. Please be aware that this Privacy Policy does not apply to these websites. Additionally, the Website includes functionality that allows integration with third-party websites, such as Twitter, Facebook, or other social networks, that allow you to share information, rich media, and other content, including your information, with such third-party websites, and you may be permitted to export information concerning your use of the Website to such third-party websites. Some of those third-party services provide us with your information to enhance and personalize your use of the Website. If you submit your credentials (e.g., username and password) for a third-party website or service during your registration for the Website or in connection with updating your user profile, we may receive your information from such third-party website or service. The Company encourages you to read the privacy statements and terms and conditions of linked or referenced websites you enter. These third-party websites may send their own cookies and other tracking devices to you, log your IP address, and otherwise collect data or solicit personal information. THE COMPANY DOES NOT CONTROL AND IS NOT RESPONSIBLE FOR WHAT THIRD PARTIES DO IN CONNECTION WITH THEIR WEBSITES, OR HOW THEY HANDLE YOUR PERSONAL INFORMATION. PLEASE EXERCISE CAUTION AND CONSULT THE PRIVACY POLICIES POSTED ON EACH THIRD-PARTY WEBSITE FOR FURTHER INFORMATION.

VI. ACCESS TO, MODIFICATION OF, AND CORRECTION OF YOUR PERSONALLY IDENTIFIABLE INFORMATION

You may opt-out of marketing communications at any time. Following registration, you may request that we provide you the information we hold about you, update your information, or ask us to remove your information (including, for example, to opt-out of marketing), or to correct any inaccuracies in such personal data by sending an email to info@patronspirits.com. We will use reasonable efforts to deal with your request within a reasonable time.

VII. REFERRAL SERVICE

Depending on the country in which you are located, the Website’s referral service may allow you to tell a friend about the Website or certain content on the Website by submitting your friend’s name and email address to us. If permissible in your country, we will automatically send your friend a one-time email inviting him or her to visit the Website. The Company stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. Your friend may contact us at info@patronspirits.com to request that we remove this information from our database.

VIII. YOUR CALIFORNIA PRIVACY RIGHTS

Residents of the State of California have the right to request from certain businesses with whom the California resident has an established business relationship a list of all third parties to which the business, during the immediately preceding calendar year, has disclosed certain personally identifiable information for direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To obtain this information, you should send a request to info@patronspirits.com with the subject heading “California Privacy Rights.” In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California Privacy Rights requirements, and only information on covered sharing will be included in our response.

IX. WHERE WE STORE YOUR PERSONAL DATA AND INTERNATIONAL DATA TRANSFERS

The personal data that we collect from EU users may be transferred to and stored at a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. We will ensure that when personal data is transferred to countries that have different standards of data protection, appropriate safeguards to adequately protect the personal data are implemented to enable such data transfers in compliance with applicable data protection laws. We have implemented Data Transfer Agreements based on EU model clauses to cover international data transfers and EU users can obtain a copy of these agreements by contacting the Company at privacy@patronspirits.com.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

X. REVISIONS TO OUR PRIVACY POLICY

We reserve the right to change the Privacy Policy at any time. Please review the contents of the Privacy Policy frequently, as the Company may amend them from time to time to reflect changes in its services and policies relating to data privacy. Amendments will become effective when posted on the Website. The Company will provide notice of any changes in the Privacy Policy via the Website. It is your responsibility to monitor and review any updates to the Privacy Policy. Your continued use of the Website, or online services provided by the Company, after such posting will be deemed your acknowledgement of these changes to the Privacy Policy.

XI. DATA CONTROLLER & CONTACT INFORMATION

The Company entities responsible for the collection and use of your personal information (the data controllers) for the purposes described in this Privacy Policy are listed below and can be contacted for any clarification or additional information you may need in order to fully understand this Privacy Policy:

Patrón Spirits International AG Quaistrasse 11 8200 Schaffhausen Switzerland +011 (41) 52 630 0540 privacy@patronspirits.com

The Patrón Spirits Company 6380 S. Valley View Blvd., Suite 210 Las Vegas, NV 89118 USA (702) 262-9450 privacy@patronspirits.com

 

XII. EFFECTIVE DATE OF POLICY

This Privacy Policy is effective and was last updated on December 3, 2018.