Corporate Privacy Policy

This privacy policy (the “Privacy Policy”) applies to the following persons (“you”):

• All visitors to our website and any online registration forms for our events or surveys – together the “Digital Media”;
• Suppliers and individuals within supplier organisations;  
• Customers and individuals within customer organisations; 
• Visitors to our premises; and
• Other stakeholders with whom we engage with. 

This Privacy Policy may be updated at any time as a result of, among others, legal, technical or commercial changes. We will notify you, by appropriate mean, of any substantive change in this Privacy Policy. You are also invited to regularly read this Privacy Policy to make sure you are aware of the latest version. 

1. Who is the data controller for the processing of your personal data?

The data controller for the processing of your personal data means the entity that determines “why” and “how” your personal data are used. 

1. The Absolut Company International AB (company registration number 556036-0579), with its registered address at S-117 97 Stockholm Sweden, acts as the data controller for most  of the processing of personal data in scope of this Policy, e.g. any use of Digital Media, for any suppliers and customer relationships mainly related to sales or marketing, or when you are visiting the office in Stockholm. 
2. The Absolut Company AB (company registration number 556015-0178), with its registered address at Box 83, 296 22 Åhus, Sweden, acts as data controller for all suppliers and customers relationship which business mainly relate to manufacturing, or when you are visiting the office and production facilities in Åhus. 

For the purposes of this Policy, The Absolut Company International AB and The Absolut Company AB will be referred to as “TAG Sweden” or “we”, “our”, “us”.  

2. What personal data do we collect about you and how?

“Personal data” refers to any information that may identify you directly (e.g., your name) or indirectly (e.g., your phone number, postal/email address, pseudonymized data such as a unique identifier).

We collect most of the personal data directly from you, for example by filling out a contact form, subscribing to a service, registering and attending to an event, during courses and testing, when requesting information, if you or your organisation orders or provides goods or services from us or to us or when you are guest to our offices. 

We may also collect personal data from cookies on our website (see for more detailed our Cookie Policy). We may also collect data from publicly accessible sources, from credit reference agencies, from customer or supplier due diligence providers, or via our CCTV or visitor registration systems. 

Depending on the purposes of collection, personal data collected are the following:

• your name and contact details, email address, phone numbers, and, where applicable, your business contact details and company details; 
• information allowing us to verify and check your identity, such as your date of birth;
• location data;
• your contact history; 
• information on how you use our Digital Media;
• your IP address and your mobile/tablet/device identifier;
• customer service information (e.g., customer service inquiries, comments);
• content you may provide to us (e.g., images, comments, etc.);
• contractual data that we obtain by providing products or services to you (or your employer);
• contractual data that we obtain through you (or your employer) providing products or services to us;
• data that we obtain through communications with you (e.g. emails, letters or conversations). 

The personal data collected is necessary to achieve the purposes described in section 3 below. If you do not provide the personal data we request, it may delay or prevent us from providing you with products or services.

3. For what purposes and on what legal basis are personal data processed?

TAG Sweden collects and processes personal data that are relevant, adequate, not excessive and strictly necessary for the purposes pursued. 

You will find below a table listing:

• The different purposes of the processing operations (i.e. why we use your personal data);  
• The legal basis on which we rely to carry out the processing (i.e. why we are authorized to use your personal data); and 
• The TAG Sweden company which is mainly responsible for the processing activities of your personal data.

PURPOSE OF THE PROCESSING	LEGAL BASIS
Restrict access to our Digital Media to comply with applicable law or contractual restrictions	TAG Sweden’s compliance with its legal obligations
Ensure the proper functioning of our Digital Media (for example via audience measurement and statistics) through trackers such as cookies strictly necessary for the provision of an online communication service expressly requested by the user or solely intended to enable or facilitate communication by electronic means (for more information you can refer to our Cookie Policy.)  For example: for user interface customization trackers (for example, for language selection or the presentation of a service), when such customization is an expected element of the service; for trackers enabling load balancing of equipment contributing to a communication service.	TAG Sweden’s legitimate interest to ensure the proper functioning of its Digital Media. Your consent, when necessary
Optimize your user experience, provide you with advertising and content adapted to your interests through the setting of cookies on our Digital Media – for more information you can refer to our Cookie Policy.	Your consent
Handle any request or feedback you make about our products and/or services (complaints, comments, satisfaction survey, etc.) For example: management of your inquiries sent via our contact forms or contact email addresses, management of feedback provided in a satisfaction survey	Depending on the purpose of your request, the legal basis is either: If your request is not related to a product/service already purchased from/subscribed with TAG Sweden: TAG Sweden’s legitimate interest, more specifically its economic/business interest to serve your needs and allow you to communicate with us simply and efficiently; If your request is related to a product/service already purchased from/subscribed with TAG Sweden: the performance of a contract (e.g. our Terms & Conditions) between TAG Sweden and you
Managing new and existing business relationships  To evaluate and source potential business partners, collaborations, and partnerships To oversee the entire business contract lifecycle, including negotiating, signing, amending, and terminating agreements Send you transactional, legal or administrative communications For example: we may send you notices about updates to our privacy notices	For concluding a contract: performance of a contract between TAG Sweden and you (including the execution of pre-contractual measures) to fulfil any obligations derived from that contract or to provide you with the requested services / goods For managing the business relationship: TAG Sweden’s legitimate interest to manage the business relations  For legal communications: TAG Sweden’s compliance with its legal obligations
Establish any evidence necessary to defend our rights and manage pre-litigation and litigation proceedings Respond to requests from the relevant authorities and defend our rights based on our legal obligations.  For example: If we receive a subpoena or another legal request, we may need to inspect the data we hold to determine how to respond	TAG Sweden’s legitimate interest to defend its rights
Manage a merger or acquisition of all or part of Pernod Ricard or a corporate reorganization	TAG Sweden’s legitimate interest i.e. its economic/business interest to anticipate and perform a corporate operation
Handle data subjects’ rights For example: management of your request to delete to your personal data	TAG Sweden’s compliance with its legal obligations
Management of access to TAG Sweden’s premises to ensure the security and safety of its premises and people through access control and video surveillance Maintain the safety and security of our IT and ensure fight against the fraudulent use of our websites or services Retention of specific video surveillance material or data may occur to support investigation of crime or accidents, such as damage to property, theft, threat or violence.   The purpose is to secure evidence for submission to the police authorities.	TAG Sweden’s legitimate interest to ensure the security of its premises and its employees and to know which individuals are in the building in case of an emergency TAG Sweden’s legitimate interest, more specifically its business and economic interest to provide you with secure IT and services TAG Sweden fulfils a legal obligation when storing or forwarding personal data to a police authority as part of a police report or investigation

4. To whom do we disclose your personal data and why?

To internal authorised employees 

We will communicate your data to our employees who need to process your personal data for the purposes specified in Section 3 of this Privacy Policy, in particular to our digital marketing,  accounting and tech teams. Your personal data can also be processed by employees from Pernod Ricard Group’s affiliates worldwide, in particular from our Brand companies, where Pernod Ricard affiliates provide support services (IT, administrative, marketing support) as processor of TAG Sweden.  

To service providers

• For IT support purposes: we will share your data with our IT support service providers (for hosting, maintenance and technical support services) to help us for the internal operations of our Digital Media and to assist us with administering them or the various features, programs and promotions available on it.
• For marketing and communication purposes, including to manage events: we will share your data with our marketing and communication service providers such as marketing agencies and digital agencies to help us carry out events, and manage your contacts and queries.
• For security purposes: we may also disclose your data to our CCTV providers and outsourced security providers, and data will not ordinarily be released to third parties unless satisfactory evidence has been provided that it is required for legal proceedings.

To other third parties

• For marketing communication purpose, we may disclose your personal data to our business partners only with your consent. In this context, your data is processed by the partner in question, who acts as the data controller. In such case, your data are subject to the data controller’s general terms and conditions and to its own personal data protection policy. We recommend that you carefully review such information/documents before consenting to the disclosure of your data to our partners.
• To fulfil our legal or contractual obligations or for risk management purposes, we may disclose your personal to our insurers and brokers, external auditors, professional advisers, banks and other third parties which provide services to us.
• For litigation and safety purposes: we may also disclose your personal data to authorities and/or external counsels if we are required to do so by law, or if in our good faith judgment, such action is reasonably necessary to comply with legal processes, to respond to any claims, or to protect the security or rights of TAG Sweden, its customers, or the public.
• In the event of a merger or acquisition of all or part of TAG Sweden by another company, or in the event that TAG Sweden were to sell or dispose of all or a part of the TAG Sweden business, the acquirer may have access to the information maintained by that TAG Sweden business, which could include personal data, subject to applicable law. Similarly, personal data may be transferred as part of a corporate reorganization, insolvency proceeding, or other similar event, if permitted by and done in accordance with applicable law. If applicable, the acquirer who will act as the new data controller will process your personal data in the conditions provided in the acquirer’s privacy policy. 

5. Is your Personal Data sent to recipients outside the European Union?

TAG Sweden is part of the Pernod Ricard group of companies and your personal data may be transferred to countries outside the European Economic Area, where Pernod Ricard Affiliates and third parties operate, such transfers will take place only if permitted and carried out in compliance with applicable laws. For these transfers, TAG Sweden takes the appropriate measures to maintain security of the personal data both during transit and at the receiving location and ensure that countries have been deemed as providing an adequate level of protection by the European Commission, or that third parties implement relevant safeguards provided by applicable laws i.e. the Standard Contractual Clauses as set out by the European Commission or, where applicable, Binding Corporate Rules. You may obtain a copy of these safeguards at any time: to do so, please contact TAG Sweden at the email address specified in section 10 of this Privacy Policy.

6. How long do we keep your personal data?

We will store the personal data that you sent to us in our databases as long as your account is active, for the duration of the contract with you or as needed to provide you the services you requested or to answer queries or resolve problems, or else to provide improved and new services. 

We may also retain your personal data in accordance with our internal retention procedure as necessary to comply with our legal and regulatory obligations, resolve disputes and enforce our agreements. 

Recorded video material from CCTV is generally stored for a maximum of 10 days. If the recorded material is relevant to an investigation, dispute resolution or incident reporting, it will be deleted once the investigation is concluded and it is no longer necessary to retain it for evidentiary purposes.

7. How do we secure your Personal Data?

TAG Sweden takes all necessary technical and organizational measures to protect the confidentiality and security of your personal data collected via our Digital Media or otherwise. These efforts include but are not necessarily limited to: (i) storing your personal data in secure operating environments to which the public does not have access, but only authorized TAG Sweden employees, and our agents and contractors; and, (ii) verifying the identities of registered users before they can access the personal data we maintain about them.

Our Digital Media may link up users to other websites of third parties and/or affiliates or subsidiaries of TAG Sweden, through hyperlinks; this is a service available to you as a user of the site. Such links do not constitute an endorsement by TAG Sweden of the linked sites, their content, including products, advertising or any other materials featured on them. TAG Sweden has no control over these linked sites and cannot be held responsible or liable for their content, including products, advertising or any other materials featured on them, or any purchase you may choose to make on these linked sites.

8. What are your rights regarding your Personal Data?

You have the following rights with respect to your personal data:

• If your personal data has been processed on the basis of your consent, you can withdraw your consent at any time (see the table in section 3 of this Privacy Policy to understand which processing are based on your consent). 
• You have the right to obtain a copy of the personal data we hold about you.
• You can request to rectify your personal data if they are inaccurate, incomplete or out of date.
• You can request the erasure of your personal data (i) if your personal data is no longer necessary for the purposes mentioned above in section 3, (ii) if you have withdrawn your consent for a data processing based exclusively on such consent, (iii) if you have objected to the data processing, (iv) if the personal dataprocessing is unlawful, (v) if the personal datamust be erased to comply with a legal obligation applicable to TAG Sweden. Please note however that this is not an absolute right, as we may be obliged to retain your personal data for legal or legitimate reasons.  
• You can request the restriction of the processing. You may ask us to restrict the processing of your personal data in specific cases (e.g., if you contest the accuracy of your personal data).
• You have the right to data portability, meaning to receive (and transmit to another data controller) personal data that you have provided to us and that we hold about you in a structured, commonly used and machine-readable format. This applies only where the processing is based on your consent or the execution of pre-contractual measures / performance of a contract and is carried out by automated means (see the table in section 3 of this Policy to understand which processing rely on these legal basis). 
• You have the right to object to the processing of your Personal Data by us, at any time, if the data processing is based on the legitimate interest of TAG Sweden, except if we can demonstrate compelling legitimate grounds for the processing – (see the table in section 3 of this Privacy Policy to understand which processing are based on TAG Sweden’s legitimate interests).

To exercise all these rights, you can send a request to: tacprivacyboard@pernod-ricard.com. 

You are informed that you can also lodge a complaint with the supervisory authority of the country where you are located if you have any concern about the conditions of processing of your personal data by TAG Sweden. In Sweden, you can contact the Swedish Data Protection Agency Integritetsskyddsmyndigheten via their website at: https://www.imy.se/

However, we invite you to contact TAG Sweden at the address below before filing any complaint before any supervisory authority.

9. How do we treat children’s Personal Data?

Our websites or services/goods are not intended for children under the legal drinking age (“Minor”), we have implemented an age gate so we do not knowingly collect personal data from Minors. If we are notified or learn that a Minor has submitted personal data to us, we will delete such personal data.

10. How can you contact us?

If you have any questions, complaints, or comments regarding this Privacy Policy or our information collection practices, please contact us either: 

• by writing to: Privacy Champion, The Absolut Company International AB and The Absolut Company AB, S- 117 97 Stockholm, Sweden or by sending an email to tacprivacyboard@pernod-ricard.com 
• or by writing to: Data Protection Officer, Pernod Ricard SA, 5 Cours Paul Ricard 75008 Paris Cedex 8 France or by sending an email to groupdpo@pernod-ricard.com