Patrón Spirits International AG
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.
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).
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.
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.
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.
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.
- 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:
|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|
|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:
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. 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.
- 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.
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.
V. THIRD-PARTY WEBSITES
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 email@example.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 firstname.lastname@example.org 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 email@example.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 firstname.lastname@example.org.
XI. DATA CONTROLLER & CONTACT INFORMATION
|Patrón Spirits International AG Quaistrasse 11 8200 Schaffhausen Switzerland +011 (41) 52 630 0540 email@example.com||The Patrón Spirits Company 6670 S. Valley View Blvd. Las Vegas, NV 89118 USA (702) 262-9450 firstname.lastname@example.org|
XII. EFFECTIVE DATE OF POLICY