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ANNUAL REPORT2023-2024

Privacy policy

INTRODUCTION

Our Privacy Policy (the “Policy”) describes how we collect, use and protect personal data (i.e. any information relating to an identified or identifiable person, referred to as a “Data Subject”) on the website www.remy-cointreau.com and in the context of the services provided by CLS RÉMY COINTREAU, with the exception of Rémy Cointreau Ethics Line (collectively, the “Services”). To learn more about the processing of your personal data in the context of Rémy Cointreau Ethics Line, please refer to the Privacy policy annexed to the Whistleblower Charter. This Policy and the Cookies Policy (Section 6) cover all users, including those who use the website and the Services without being registered or subscribing to a specific service (hereinafter collectively, the “Users” or “you”).

This website is operated by CLS RÉMY COINTREAU, located at 21 rue Balzac, France, which is an entity of the Rémy Cointreau Group. For the purpose of this Privacy Policy, CLS RÉMY COINTREAU is designated by “RÉMY COINTREAU” or by “we”.

RÉMY COINTREAU acts as a data controller with regard to the applicable legislation and regulations on data protection, in particular: (i) the UK General Data Protection Regulation and the Data Protection Act 2018; (ii) the Privacy and Electronic Communications Regulations 2003 (which are derived from the Privacy and Electronic Communications Directive 2002/58/EC); (iii) the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation, hereinafter the “GDPR”), which entered into force on 25 May 2018; and (iv) all applicable laws, statutes, statutory instruments, orders, regulations and codes of practice (whether or not having the force of law) in force from time to time and which apply to the processing of your personal data- hereinafter collectively referred to as the “Applicable Laws”.

 

1. INFORMATION WE COLLECT

Depending on the Services selected, and the choices and settings you have made on your device (in particular with respect to cookies), the personal data concerning you (your “Personal Data”) that we collect and process mainly includes:

  • Data relating to your identity and contact details (surname, first name, email address, telephone number, etc) where you choose to provide them, for example to receive our publications, press releases or news, as well as any other information you may disclose when contacting us or when registering to RÉMY COINTREAU Services;
  • Data relating to your social networks (account username, comments, etc) when interacting with RÉMY COINTREAU on social networks;
  • Marketing data relating to your preferences and interests including your browsing habits, notification preferences (email/phone) and other information that you might share with us, to carry out loyalty and prospecting actions or any requests made to our customer service department;
  • Information regarding articles that you request to receive by email;
  • IP address, cookies, trackers, and similar techniques to analyse how you use our Services and how we provide certain features to you. For more information on how we use cookies, please see our Section 6.

Third Party Services published by third party companies not affiliated with RÉMY COINTREAU and link to social networks may be associated with website. These links to other websites should not be considered as navigation tracking and RÉMY COINTREAU declines any responsibility concerning the personal data protection practices implemented by these third-party companies, each of which acts as a separate data controller of your personal data on their own perimeter. Once you leave the website or click on the logo/link to one of these website/social networks, it is your responsibility to check the privacy policy applicable to that other website/application.

The Personal Data we necessarily need for the purposes described below are indicated (most of the time by an asterisk) on the various pages of the website. Without this mandatory data, we will not be able to respond to your requests and/or provide you with the requested services. The other personal data are purely optional and are intended to get to know you better and to offer you better services.

 

2. PURPOSE OF PROCESSING

We use and process Personal Data about you for the purposes described below:

  • To check that you meet the minimum legal age requirements for the products or services requested (legal obligation);
  • To supply products or services requested (legitimate interest and/or performance of a contract);
  • To respond to your requests, comments and complaints (legitimate interest);
  • To understand your interests and your preferences in order to personalize your experience and to tailor our marketing activities to your needs (legitimate interest);
  • To send commercial communications, especially our publications, press releases and news, provided that you have given your prior consent or ordered a similar product or service or provided that you are a professional (legitimate interest or consent);
  • To carry out analysis of statistics concerning our marketing campaigns and the activity of the website (legitimate interest or consent);
  • To manage the security of the website and protect it from fraud, theft or any other illegal activity that may affect our services (legitimate interest);
  • To improve our website and provide you with technical support (legitimate interest);
  • To comply with our legal obligations (legal obligation).

We undertake not to process your Personal Data in a way that would defeat the purpose for which it was collected and to collect only the Personal Data that is necessary for the purposes stated.

 

3. YOUR RIGHTS

In accordance with the Applicable Law, you have the rights of access, rectification, erasure, restriction of processing, objection, portability of your personal data we hold about you to the extent applicable, unless we can demonstrate a compelling legitimate reason for retaining your Personal Data.

When the Processing is based on your consent, you have the right to withdraw your consent at any time.

You can ask us to stop sending you information regarding our offers, news and events at any time by using the unsubscribe link in every email we send you.

In addition, you have the right to lodge a complaint with your local data protection authority, the Information Commissioner’s Office, in the United Kingdom. You can exercise your rights by using your account settings or by writing to us at: privacy@remy-cointreau.com.

Please bear in mind that if we feel that your request is vague, we may discuss with you to better understand the reason for your request and ask you to prove your identity (e.g. by asking you to produce identification). We need to ensure that your request does not infringe any third-party rights.

 

4. DATA RECIPIENTS

Your Personal Data will not be transferred to or made accessible by third parties, except in the following cases:

  • the other entities of the Rémy Cointreau Group after obtaining your consent or for internal administrative purposes;
  • our service providers (e.g. hosting providers, advertising partners, marketing and advertising agencies) internal or external to Rémy Cointreau’s group;
  • our external advisors (lawyers, accountants, auditors etc.);
  • in the event of a change of control, if we sell or otherwise transfer all or part of RÉMY COINTREAU or our assets to another company (e.g. in a merger, acquisition or liquidation) and;
  • when such disclosure is required by a legal or regulatory provision or by a court decision, or when such disclosure is necessary to ensure the protection and defense of rights or to avoid possible damage.

 

5. TRANSFERT OF PERSONAL DATA & SECURITY MEASURES

We may transfer your personal data to another country outside of the UK and European Union. Where we transfer your data to such third countries (e.g. for transaction processing and fraud prevention purposes), we ensure an adequate level of protection for the transferred personal data by entering into data transfer agreements with the recipients of your personal data based on the European Commission’s standard contractual clauses (“SCCs”) or other valid transfer mechanisms and we carry out, in accordance with the European Court of Justice’s decision of 16 July 2020 “Schrems II” (Case C 311-18) and with the guidance of the European Data Protection Board, a risk assessment of the transferred data. Please contact us if you would like to receive a copy of the safeguards in place to secure data transfers outside the UK and the European Economic Area.

Data is processed both manually and electronically and is protected by appropriate security measures. We will provide an adequate level of protection for your data and ensure that appropriate technical and organisational security measures are in place to protect your data against accidental or unlawful destruction, accidental loss or alteration, unauthorised disclosure or access and against all other forms of unlawful processing.

The same level of protection is contractually imposed by RÉMY COINTREAU on all its subcontractors. Any employee of RÉMY COINTREAU who, in the course of his or her duties, may have access to your personal data undertakes to hold it in strict confidence. However, as the Internet is not completely secure, we cannot guarantee that your personal information stored or sent will be completely safe. We encourage you to exercise caution when using the Internet to access our website.

 

6. COOKIES

This section on cookies explains how we use cookies to provide, protect and improve our website.

List of cookies

A cookie is a small data file (text file) that a website, when visited by a user, asks your browser to store on your device in order to remember information about you, such as your language preferences or login details. We set these cookies as internal cookies. We also use third-party cookies, which are cookies from a different domain than the website you are visiting, for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:

Functionality cookies

These cookies are used to improve and personalize the functionality of the website. They may be activated by our teams, or by third parties whose services are used on our website pages. If you do not accept these cookies, some or all of these services may not function properly.

Performance cookies

These cookies enable us to determine the number of visits and sources of traffic, in order to measure and improve the performance of our website. They also help us to identify the most/least visited pages and to evaluate how visitors navigate the website. All information collected by these cookies is aggregated and therefore anonymized. If you do not accept these cookies, we will not be informed of your visit to our site.

Strictly necessary cookies

These cookies are necessary for the operation of the website and cannot be deactivated in our systems. They are generally set in response to actions you perform that constitute a request for services, such as setting your privacy preferences, logging in or filling in forms. You can configure your browser to block or be informed of the existence of these cookies, but some parts of the website may be affected. These cookies do not store any personally identifying information.

In order to meet these purposes, we use partners, listed in this section, who may deposit cookies in your browser on our behalf. In some cases, these cookies may track your browsing beyond our website. Through these cookies, our partners collect and use your browsing data for the above purposes. For more information, we encourage you to review their privacy policies.

Consent Management

When you first visit our website, you will be asked to accept or decline the use of certain cookies. You can change your choices at any time by clicking on “Cookies” tab.

Managing cookies in your browser

Without your explicit consent, no cookies are deposited on your device. Thus, the refusal to deposit cookies is set by default.

When you make a choice (acceptance or refusal to deposit all or part of the data), we keep your choice for a period of 6 months from the date of collection.

In order to manage your cookie expectations as precisely as possible, you can also change the settings of your web browser. Below you will find links to support pages for disabling cookies on the most commonly used browsers:

If you refuse to accept cookies that are strictly necessary for the website to function, or if you delete the cookies stored on your terminal, you will no longer be able to benefit from a certain number of functions that are nevertheless necessary to use the website. This would be the case if you attempted to access our content or services that require you to be identified. This would also be the case if we – or our service providers – were unable to recognize, for technical accounting purposes, the type of browser used by your terminal, its language and display settings or the country from which your terminal appears to be connected to the Internet.

Where applicable, we decline all responsibility for the consequences linked to the degraded functioning of our services resulting from the impossibility for us to record or consult the cookies necessary for their functioning and which you would have refused or deleted.

Duration of data retention

Cookies are stored on your terminal for as long as is necessary to achieve the purposes pursued, as described above. In particular:

  • Cookies, which may or may not require your consent, are stored on your device for a maximum of 13 months after they are created;
  • The information collected via cookies is kept for 25 months from the date of their creation on your terminal.
  • Your choice, consent and/or refusal, regarding cookies is retained for a period of 6 months (after this period we will ask you again to choose how you wish to manage your cookies on our website).

 

7. DATA RETENTION

Your Data will be retained, in a form that allows you to be identified, only for as long as is necessary for the purposes described in this Privacy Policy, or for as long as is necessary to comply with any legal obligation. Please note that the length of time required by law to retain data may vary from country to country.

For example:

  • The data of prospects will be kept for a period of 3 years after the collection of the data or the last contact. After this period, the data will be deleted or anonymized.
  • In the event that RÉMY COINTREAU is required to fulfil a legal obligation, your data will be processed for the time necessary to fulfil this obligation and as provided by law;
  • If you request to unsubscribe, your Personal Data will be destroyed within a maximum of 30 days.

 

8. CONTACT US

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact our Data Protection Officer by sending an email to privacy@remy-cointreau.com.

RÉMY COINTREAU may change or update this Privacy Policy at any time, so please review it regularly. We will provide further notice of changes or updates as appropriate.

Last update: June 2024