Pernod Ricard Japan (hereafter, “Company”) recognizes that appropriately handling customers’ personal information is an important corporate responsibility, and accordingly does its utmost to protect such information.

Pernod Ricard Japan

1. Policy Overview

Regarding the handling of personal information, the Company endeavors to appropriately use and protect the important information that it receives from customers.

Given the nature of its business activities, the Company recognizes the importance of properly handling personal information, and continuously endeavors to improve its management practices for personal information.

The Company endeavors to deal appropriately and promptly with customers’ inquiries and requests about the handling of their personal information.

The Company scrupulously obeys the Act for the Protection of Personal Information and other relevant laws and ordinances.

The Company follows this personal information protection policy (hereafter, “Policy”) in handling the personal information that it obtains through the Company’s employees, etc.

2. Definition of Personal Information

In this Policy, personal information refers to information related to individuals that falls under the following definition.

Definition

Personal information is information related to existing people that the Company acquires through its commercial transactions, marketing campaigns, and other corporate activities; that can be used to identify individual customers by means of their name, address, date of birth, telephone number, email address, content of inquiries, and other factors; and other information that is stipulated in each Item of Article 2, Paragraph 1 of the Act for the Protection of Personal Information. Personal information also includes other information which cannot by itself be used to identify an individual but which can easily be combined with other information to achieve identification as a result.

3. Types of Personal Information

The personal information mentioned below and other necessary personal information may be acquired through interactions, transactions, etc. with customers.

• Name, address, date of birth, sex, phone number, email address and other contact information
• Preferences and purchasing history for the Company’s products
• Other personal information necessary for the Company to provide its products and services

4. Methods of Acquiring Personal Information

We acquire personal information related to customers through interactions, transactions with customers, their registration in marketing campaigns, their registration for newsletters, and through other methods.

5. Purposes for Using Personal Information

When necessary, the Company uses personal information related to customers for the following purposes.　The Company’s group companies (Pernod Ricard S.A., Pernod Ricard S.A.S., etc. The same shall apply hereafter.) use, for the following purposes, the personal information, etc. for which the customer in Japan is the principle if such group companies handle such information in a foreign country in relation to providing products and services to the customers in Japan.

• To accept registration and identify individuals on the Website which the Company manage currently and in the future
• To send and provide purchased and ordered products and services, and to provide other services including communication related to transactions
• To provide information of services including experience involving customer participation (mainly event) and special offer as well as the services incidental to those (including sending prizes)
• To ask for opinions, thoughts, etc. in order to improve the quality of the services
• To distribute the newsletter about the Company’s products, services, offers
• To provide necessary communication for performing the services related to campaigns and special offers
• To analyze the trend of demand and purchase in the aspect of the Company’s sales promotion and marketing
• To request participation in questionnaires coordinated by the Company and to send reward for answering it
• To respond to inquiries, etc.
• To send customers information about the Company’s products, events, etc. by email or other means
• To conduct direct marketing [to send marketing materials directly to customers] (when the customer’s consent has been obtained; customers may also refuse to accept marketing materials)
• To handle affairs relating to settlement of the purchased products
• To disclose or transfer to a third party within the scope which the laws and regulations allow

6. Providing Personal Information

The personal information and peｒson-related information which the Company acquires on the website it currently operates or will operate in the future will be provided to the Company’s Group company (a third party), and its outsourcing companies and will be acquired as personal data including peｒson-related information. EU has a system for personal information protection which is recognized to meet the standard similar to that of Japan from the aspect of protection of rights and interest of individuals.

Also, in the following situations, personal information and peｒson-related information related to a customer may be provided to a third party or other outside party to the extent necessary.

• The customer’s consent is obtained in advance.
• Providing the information is required or allowed under the laws and regulations.
• Providing the information is necessary to protect somebody’s life, body or property and it is difficult to obtain the customer’s consent.
• Work is outsourced after appropriate safety management is conducted.
• The information is used jointly with a specific party as provided for under the laws and regulations.
• Other situations where providing the information to a third party is allowed under the laws and regulations

Other than the foregoing, the Customer‘ｓ name, email address, date of birth, billing address, purchase history, etc. out of the personal information which the Company acquires on the website it currently operates or will operate in the future will become accessible to the Company’s Group company in foreign countries if the Customer consents on the website which such group companies currently operate or will operate in the future. Since it is the Customer’s future decision to allow which group company in which country to access the personal information above, it is currently not possible to specify such country and to provide information about the measure such company takes.

7. Providing the Personal Information of Third Parties by Customer

The Company may acquire from Customers personal information (excluding that in the form of database) such as contact information of their friends and other third parties only if the consent of the principal of the said personal information has been obtained. In such a case the Company will promptly inform the principal of the purpose of use.

8. Disclosure, Correction, etc., of Personal Information

When a customer requests that personal information related to the customer be disclosed, corrected, deleted, or no longer used, then the Company, after identification, provide the requested action such as answer and correction, in accordance with the laws and regulations.

9. Management of Personal Information

The Company continuously takes appropriate measures to ensure that the personal information related to customers is accurate and updated. It also makes effort to take the necessary measures for risks to customers’ personal information, such as unauthorized access, loss, leakage, damage, etc. Moreover, it conducts necessary and appropriate supervision of its employees and outsourcing companies.

10. Inquiries from Customers about Personal Information

For inquiries from customers about the handling of their personal information, the Company has established an inquiries desk that deals promptly and appropriately with such matters.

For inquiries, contact: VIPConcierge@pernod-ricard.com

11. Reviewing of Policy

In response to changes in the environment and other factors, the Company constantly reviews this Policy in order to appropriately protect the personal information of customers.

12. Language

The official language of the private policy shall be Japanese and any version translated into other language shall be for reference and in any and all cases, Japanese version shall prevail.

Enacted on November 16, 2021

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