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LAST UPDATED: 5 December 2017
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© 2017 Brown-Forman Corporation. All Rights Reserved.
LAST UPDATED: 16 March 2018
Whenever you access our products or services or interact with us in other ways, Brown-Forman Corporation and its affiliated companies (“Brown-Forman”) collect and use (process) information about you (referred to as your “personal information”). This notice describes how we collect personal information and how we use, share and protect it. It also explains your rights regarding your personal information and how you can contact us.
Since this notice contains important information, we encourage you to read it. Please use the links to access detailed information. If anything is not clear, please contact us via email at [email protected]
In this privacy notice we describe:
WHO COLLECTS YOUR PERSONAL INFORMATION
Brown-Forman is a group of companies, headed by Brown-Forman Corporation in the United States and with local entities throughout the world. Which of the Brown-Forman companies is responsible for collecting and processing your personal information depends on how you interact with us and where you are located in the world.
Please review the country specific information for the name and contact information of the relevant Brown-Forman entity as well as additional information relevant to each country. Whenever we refer to “we” or “us” in this notice we mean the relevant Brown-Forman entity.
INFORMATION THAT WE COLLECT
In order to make our services available to you, or to meet a legal obligation, we need to collect and use certain personal information. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Some of this information we collect directly from you either in person or via a website, application or social media. We also collect personal information about you from other sources.
When we receive personal information about you from different sources, we may combine or link that information. Linking different sources of information enables us to provide a better customer support service when you contact us and to provide you with personalized services, content and marketing.
Please click on the links to learn more:
We collect personal information when you:
We collect personal information from you, which might include:
We also collect personal information from other sources:
HOW WE USE YOUR PERSONAL INFORMATION
We use your personal information for legitimate business purposes as described further below. Please click on the links to learn more.
Providing access to our services:
We may use your personal information to provide you with the functionality of our services, events and mobile applications, such as by arranging access to a registered account. We may also use personal information to send you administrative information, such as changes in our terms, conditions and policies. We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
Administering prize promotions, offers and events:
We may conduct prize promotions, contests and other promotional offers. If you participate, we will use your information to administrate such promotions and offers. If you are lucky enough to win, we might ask you for further information so that we can provide your prize and we will ask you to provide a copy of your photographic ID so that we can verify that you are of legal purchase age and, if required, to satisfy eligibility requirements. Some of these promotions have additional rules containing information about how we will use and disclose your personal information. We use this information to manage our contractual relationship with you.
If you contact us, or we contact you, we will use your personal information such as your purchase information and contact history for the purpose of providing you with assistance, handling enquiries and complaints. We will engage in these activities to manage our contractual relationship with you, for our legitimate business reasons and/or to comply with a legal obligation.
Processing your order:
We use information about you to process your orders (including to determine that you meet the legal purchase age in your country), to take payment for items you have purchased from us, to dispatch items you have purchased or to process a return or request for a refund. We may also use your data to protect against or identify possible fraudulent transactions. We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
Sending you information about our (and third parties') products and services:
Where you have asked to receive marketing communications from us, we may send you information about our products, newsletters, promotions, offers or other information that we think might be of interest to you. We use personal information to send you marketing communications. You also may receive marketing communications from Brown-Forman if you have consented to receive alcohol marketing messages from an approved third-party partner. We will engage in these communications either because we have a legitimate interest or with your consent.
If you decide to opt-out from marketing messages, you may opt-out by clicking here.
We will seek to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing communications from us, we may still send you important administrative messages, from which you cannot opt-out.
Our business purposes
We use the personal information we hold about you to accomplish our business purposes, including:
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
Personalizing our services:
We may analyze personal information collected for business reporting and providing personalized services, including: (i) to analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our services; (ii) to better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests; and (iii) to better understand your preferences so that we can deliver content via our services that we believe will be relevant and interesting to you. When you use one of our online stores, we will collect information from you during the checkout process. If you do not complete your purchase but ask us to save your basket, we will send you a follow-up email with a reminder of its contents. We may also use your information to provide personalized content and recommendations when we send you information about your purchases. We will provide personalized services either with your consent or because we have a legitimate interest.
We may use information collected from monitoring our websites, online services and emails to protect you, our employees and our partners. This information may be passed to the police or to other appropriate authorities. We will engage in these activities to comply with a legal obligation or because we have a legitimate interest.
HOW WE SHARE PERSONAL INFORMATION
We share your personal information with your consent or as necessary to complete any transaction or provide any service you have requested. We do not share personal information with unaffiliated third parties at this time. The following are categories of recipients with whom we might share your data. Please click the links to learn more.
Other companies within the Brown-Forman Group:
Third party service providers:
We use third party service providers to process personal information on our behalf. These may include the provision of customer support, web hosting providers, customer data management and list enhancement companies, agencies that run our prize promotions, companies that fill product orders or coordinate mailings, delivery companies, payment processors, data analysis firms and email service providers. We seek to use service providers who are able to provide appropriate data privacy and security standards.
When you share personal information:
Business transactions, legal reasons and law enforcement:
We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
We may also disclose personal information to comply with legal obligations (such as paying taxes); to respond to requests from government or other public authorities; to protect the rights, privacy, safety or property of Brown-Forman, you or others; and to permit us to pursue available remedies or limit the damages that we may sustain. These legal obligations and government requests can include laws and authorities outside your country of residence.
OTHER INFORMATION WE COLLECT
We and our service providers also may collect other information that does not reveal your specific identity or does not directly relate to an identifiable individual (referred to as “other information”). This may include:
If we are required to treat other information as personal information under applicable law, then we may use and disclose it for the purposes for which we use and disclose personal information detailed in this Policy.
Other information may be collected in a variety of ways, including:
We and our service providers may also use so-called "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some Website pages and HTML-formatted e-mail messages to, among other things, compile aggregate statistics about Website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1) that is ordinarily not visible to Website visitors and may be associated with Cookies on the visitors’ hard drives. When used in HTML-formatted e-mail messages, Pixel Tags can tell the sender whether and when the e-mail has been opened.
We may collect the physical location of your device if you use a location-based service. Before this information is collected, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
USES AND DISCLOSURES OF OTHER INFORMATION
We may use and disclose other information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine other information with personal information. In those instances we will treat the combined information as personal information while it is combined.
YOUR RIGHTS TO YOUR PERSONAL INFORMATION
You may request to access, correct or remove your personal information. You also may request to receive an electronic copy of your personal information to transmit it to another company (to the extent this right to data portability is provided by applicable law). In each case, we may require you to prove your identity and/or provide further information in order to identify your information. We will respond to your requests consistent with applicable law. Please click the links to learn more.
Accessing your personal information
You may ask to see what information we hold about you and to receive an explanation about how we process your data by using the “contact us” form.
Correcting your personal information
If we hold personal information about you that is incorrect, you have the right to tell us that it is incorrect and ask us to amend it. We will do this consistent with applicable law. If you would like to correct your personal information, please send an email to [[email protected]].
Removing your personal information
You may ask us to remove or delete your personal information from our database. If you do not want to receive promotional emails, please click here. If you wish to have your personal information removed from our database, please send an email to [[email protected]].
You may ask us to port your personal information from our database, please send an email to [[email protected]].
OTHER IMPORTANT INFORMATION
We take the security of your information very seriously. This section outlines our technology practices to keep your information protected. Please click the links to learn more.
How we protect your information
We use various security measures and tools, such as firewalls, to help protect against the loss, misuse and alteration of the personal information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Please do not send us sensitive personal information.
How we retain your personal information
We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods for payment card information and age-verification information include:
· The length of time we have an ongoing relationship with you and provide the services to you (for example, for as long as you have an account with us or keep using the services);
· Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
· Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
International transfers of your personal information
We may transfer your information to Brown-Forman Corporation in the United States and to other service providers who may be located outside of the European Economic Area (EEA). In these circumstances we take measures to ensure that your information is protected, this includes putting in place contracts with the recipients of your information to ensure that they provide adequate protection for your information. You may obtain a copy of these measures by contacting [[email protected]].
In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.
Access to services by individuals who are underage
Our services are not directed to individuals who are under the legal age to purchase alcohol, and we do not knowingly collect personal information from such individuals.
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use Brown-Forman services and other websites or online services.
Sensitive personal information
we ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services or otherwise to us.
850 Dixie Highway
Louisville, KY, USA 40210
Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.
ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE EEA
If you are located in the EEA, you also may:
© 2018 Brown-Forman Corporation. All Rights Reserved.
The information included in this section is specific to our products and services in the United States.
There are several ways you can communicate with us. Our email address is [email protected] If you prefer to contact us in writing, please use the mailing address below:
Privacy Officer, c/o Brown-Forman Corporation, 850 Dixie Highway, Louisville, KY 40210 USA
©2018 Brown-Forman Corporation. All Rights Reserved.