Privacy
policy
INTRODUCTION
Our Privacy Policy explains how we collect, use and protect information in relation to the mobile application The Art of Cointreau (the “App” and digital services (collectively, the “Services”). The App provides a training portal to learn more about Cointreau. This Privacy Policy applies to all visitors and users (our employees or partners) who access the Services. This App is operated by COINTREAU, a simplified joint stock Company with a capital of € 4 036 944 – whose registered address is: Carrefour Molière – 49124 St Barthelemy d’Anjou France, registered in Angers under the n° 582 143 384. Cointreau operates in its capacity of data controller for the purposes of applicable data protection laws and regulations, including the Regulation (EU) 2016/679 dated 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data (“GDPR”). For the purposes of this Privacy Policy, the data controller is designated by its trademark “Cointreau”.
1. INFORMATION WE COLLECT
Depending on the Services provided by the App and used by you, on your choices and configuration of your terminal (with respect in particular to cookies), personal data concerning you (your “Personal Data”) collected and processed by Cointreau mainly includes: e-mail address, password, user name and result to the quiz. To the extent permitted by applicable law, we may combine the information collected, including information about the organization for which you work, with other information in our possession or information that you provide to us. The Personal Data that is mandatory for Cointreau to fulfil the purposes that are described below is marked with an asterisk (*) on the various pages of the App. Should you not fill in these mandatory fields, Cointreau may not be able to take care of your demands and/or to provide you the requested services. Other Personal Data is purely optional and allow us to know you better and to improve our communications and services accordingly.
When you visit the mobile App, we may use cookies, tracers and similar tracking technologies to collect information about how you use our Services and provide features to you. Cookies are used to automatically collect your device identifiers and other information about you, such as the following: Internet Protocol (IP) address, logs, webpages clicked. We may also ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party. For more information about our use of cookies, please visit our Cookie policy.
2. PURPOSES OF PROCESSING
We collect and process your Personal Data with your consent and/or as necessary to meet our legal obligations or fulfil our legitimate interests. We use and process Personal Data about you for purposes described below:
- to provide the training and send you information,
- to make statistics;
- to prevent fraud and ensure compliance;
- to improve our App and provide technical support.
We will not process your Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you or collect any Personal Data that is not required for the mentioned purposes. For any new purpose of processing we will ask your separate consent. To the extent necessary, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current. We also undertake to collect only the categories of Personal Data that are strictly required for the purposes mentioned above.
3. YOUR RIGHTS
In accordance with applicable data protection laws and regulations, you have a right to request access to, rectification or erasure of your Personal Data, or restriction of processing, and to object to said processing, as well as the right to data portability to the extent applicable, subject to any overriding legitimate grounds that Cointreau might invoke to retain your Personal Data. Moreover, you have the right to lodge a complaint with your local data protection authority about any of our activities that you deem are not compliant with the GDPR. You can exercise your rights by using your account settings or by simply writing us at the following address: privacy@remy-cointreau.com. Please keep in mind that in case of a vague request we may engage a discussion to better understand the motivation for the request and require you to prove your identity (for example, by requesting an ID). This is made to ensure that no right of third parties are violated by your request.
4. DATA RECIPIENTS
Your Personal Data shall be processed by Cointreau. It shall not be transferred or made accessible to any third party apart from:
- our service providers (such as providers of hosting and maintenance services);
- other entities of the Rémy Cointreau group;
- in case of a change of control, if we sell or otherwise transfer part or the whole of Cointreau or our assets to another company (e.g., in the course of a transaction like a merger, acquisition, liquidation) and;
- to third parties if such disclosure is required by law, by a regulatory provision or by a court ruling, or if this disclosure is necessary to ensure the protection and defense of rights or to prevent harm.
5. TRANSFER OF PERSONAL DATA & SECURITY MEASURES
Cointreau, its affiliates, or service providers may transfer information that we collect about you, across borders. If you are located in the European Union, please note that we may transfer your Personal Data to a country that does not have the same data protection laws as your jurisdiction. Any transfer of your Personal Data outside the European Economic Area shall only take place subject to appropriate safeguards being in place, such as standard contractual clauses and other contractual safeguards. You can contact us to obtain a copy of the safeguards implemented to secure data transfers operated outside the European Economic Area. We use reasonable and appropriate information security safeguards to help keep the information collected through the Services secure and take reasonable steps to verify your identity before granting you access to your account. Among others, we utilize the following security measures:
- Pseudonymization of certain categories of your Personal Data;
- Encryption of your Personal Data in transit and in rest;
- Regular vulnerability scanning and penetration testing;
- Organizational measures (access control, restriction of access);
- Conducting periodical data protection impact assessments and privacy audit.
6. DATA RETENTION
We will retain your Personal Data as long as your account is active or needed to provide you services, and only for as long as necessary in relation with purposes of processing identified in this Privacy Policy. Information we receive about you may be retained for an extended period of time when it is the subject of a legal obligation, an investigation or otherwise to prevent harm. The Personal Data that is used for the purpose of performing the training shall be kept for a period of three (3) years as of the date on which it was collected or as of your last contact with Cointreau. Your Personal Data shall be destroyed within a maximum of 30 days following any request on your part to unsubscribe. Finally, the connection logs that are collected, subject to your consent, using the cookies, tracers and other similar tracking technologies implemented on our App, shall be kept in accordance with applicable laws and regulations for a period of time that does not exceed thirteen (13) months.
7. CHILDREN’S PRIVACY
The App is not directed to users under the legal age of drinking. If you are younger this legal age, depending of your country, you may not use our Services. If you are a parent or guardian and believe we may have collected information about a child, please contact us.
8. CONTACT US
If you have any questions about this Privacy Policy and if you wish to exercise your rights, please contact our Data Protection Officer through the email or to our mailing address:
Remy Cointreau DPO
21, boulevard Haussmann 75009 Paris, France
Phone: +33 (0) 1 44 13 44 13
9. CHANGES TO OUR PRIVACY POLICY
Cointreau may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms of notice of modifications or updates as appropriate under the circumstances. Last update: July 2020
